Stigmatic removal of an Anganwadi Worker without departmental inquiry violates natural justice.

The petitioner was appointed as an Anganwadi Worker on 15.06.1994 and served at Anganwadi Centre, Village Bakan, Tehsil Aron, District Guna, for approximately 30 years.

Following inspections in which the Centre was allegedly found closed and allegations were made regarding negligence, improper conduct and non-distribution of snacks/nutritious food, show-cause notices were issued to her.

Without issuing a charge-sheet or conducting a regular departmental enquiry, the competent authority terminated her services by order dated 16.02.2024.

Her first appeal, filed before the appellate authority, was dismissed on 18.11.2024, and her second appeal was dismissed on 22.05.2026.

Whether the petitioner’s services could be terminated through a stigmatic removal order without issuance of a charge-sheet and without conducting a regular departmental enquiry?

Whether the termination order was vitiated for being non-speaking, unreasoned and contrary to the procedure prescribed under the Government policy dated 10.07.2007 and the principles of natural justice?

Whether the appellate orders dated 18.11.2024 and 22.05.2026 could be sustained when the original termination order itself was legally defective?

Under the State Government policy dated 10.07.2007 governing removal of Anganwadi Workers and Helpers, an Anganwadi Worker may be removed for negligence or failure to perform duties only after being afforded an opportunity of hearing and being found guilty in an enquiry.

A termination order founded on allegations of misconduct, dereliction of duty or improper conduct is stigmatic and ordinarily cannot be passed without a regular departmental enquiry and compliance with natural justice.

Under Khem Chand v. Union of India, reasonable opportunity includes notice of the charges, an opportunity to contest the allegations and cross-examine witnesses, and an opportunity to make a representation against the proposed punishment.

Further, under Mansukhlal Vithaldas Chauhan v. State of Gujarat and Joint Action Committee of Air Line Pilots’ Association of India v. DGCA, the competent statutory authority must independently apply its mind and cannot act at the direction or behest of an unauthorised authority.

The Court found that the removal order expressly attributed misconduct and dereliction of duty to the petitioner, including improper behaviour, failure to distribute food and keeping the Anganwadi Centre closed; it therefore carried stigma and serious consequences for her future prospects.

Despite the stigmatic nature of the allegations, the respondents neither issued a charge-sheet nor conducted a regular departmental enquiry in which the petitioner could contest the evidence, examine witnesses or adequately defend herself.

The mere issuance of show-cause notices was insufficient, particularly because the removal order was non-speaking and did not meaningfully consider the petitioner’s response.

The procedure prescribed by the policy dated 10.07.2007 required an opportunity of hearing followed by an enquiry and a finding of guilt, none of which had occurred.

The removal order dated 16.02.2024, the first appellate order dated 18.11.2024 and the second appellate order dated 22.05.2026 were quashed and set aside.

The respondents were directed to reinstate the petitioner forthwith, while retaining liberty to initiate fresh proceedings against her in accordance with law, if so advised.

The writ petition was accordingly disposed of, and any pending interlocutory application was also disposed of.