Service approvals cannot be revoked for management irregularities without specific proof of individual employee fraud.

The Petitioners are teaching and non-teaching staff (and their respective school managements) appointed in private aided schools between 2009 and 2018

Their appointments were duly approved by the Education Authorities, and they were assigned "Shalarth IDs" for salary disbursal under a 2012 Government Scheme

In March 2025, the Respondents abruptly stopped the Petitioners' salaries without prior notice

Following a news report regarding alleged irregularities and forged signatures of a deceased Education Officer, the State formed a Special Investigation Team (SIT)

In August 2025, the Respondents issued vague, undated show-cause notices alleging "unscrupulous" irregularities

Mass hearings were conducted where up to 150 employees were called simultaneously and directed only to fill out a 22-point questionnaire rather than being granted a personal oral hearing

Subsequently, the Deputy Director of Education passed orders in early 2026 cancelling the Petitioners' approvals and Shalarth IDs on grounds of roster violations and non-sanctioned posts

1. Whether the summary stoppage of salary and the issuance of vague show-cause notices violated the principles of natural justice

2. Whether the mass hearing procedure involving questionnaires instead of oral representation constituted a fair hearing

3. Whether the Respondents could validly cancel approvals and Shalarth IDs after a decade of service in the absence of specific allegations of fraud against the employees

4. Whether exacting work from teachers while withholding salary constitutes "Begar" under Article 23 of the Constitution

The Court primarily relied on the principles of Natural Justice (Audi Alteram Partem), emphasizing that a show-cause notice must be specific and not vague to allow a meaningful defense, as established in Commissioner of Central Excise v. Brindavan Beverages (P) Ltd.

It applied Article 21 of the Constitution, recognizing the right to livelihood as an integral part of the right to life

The Court applied Article 23, which prohibits "Begar" (exacting work without remuneration)

The Court further relied on Shivanee Prasanna Deshpande v. State of Maharashtra, which stipulates that approvals cannot be recalled due to departmental errors unless fraud or misrepresentation is established

The Court further relied on Hemant Baliram Deore v. State of Maharashtra, which condemned "undue haste" and mass hearings as a "farce"

The Court found the show-cause notices fundamentally flawed because they failed to specify individual charges of fraud or misconduct, rendering them unintelligible

It criticized the "mass hearing" format (150 people at a time) as a "farce" and an "eye-wash," noting that it precluded any actual application of mind to individual cases

The Court observed that since these employees had served for 10 to 15 years and had undergone annual inspections without objection, the Respondents could not suddenly cancel approvals on technical grounds (like roster points) which were the responsibility of the Management, not the employees

Crucially, the Court noted that the State continued to exact duties—including election and census work—from the Petitioners while withholding pay, which squarely fell within the constitutional prohibition of "Begar"

The Court held that unless the teachers were shown to be parties to a fraud, they could not be penalized for administrative lapses or "flaws in the system"

The Court held that the Petitioners are entitled to their full salary arrears from March 2025 and directed the Respondents to continue regular payments

While the State was granted liberty to conduct fresh enquiries, it was restricted to doing so only via specific show-cause notices alleging fraud or misrepresentation where the employee was a party; administrative irregularities must be addressed only against the Management or the defaulting officers

The restoration of Shalarth IDs and approval orders was directed immediately