Termination of Anganwadi Worker for minor misconduct without formal inquiry violates principles of natural justice and governing circulars.

The petitioner was appointed as an Anganwadi Worker on July 7, 2023

On May 14, 2025, she was served a show-cause notice alleging unauthorized absence from duty and an offer of resignation

The petitioner denied the resignation, asserting it was unsigned, and explained her absence as a result of grievances regarding Anganwadi Centre difficulties previously raised before the Collector

On July 1, 2025, the Project Officer terminated her services

Her subsequent appeals to the Additional Collector and the Commissioner, Indore Division, were dismissed without detailed reasoning

The petitioner challenged these orders under Article 226 of the Constitution, alleging they were passed without a formal inquiry and in violation of the principles of natural justice

1. Whether the termination of the petitioner’s services without a formal inquiry was in violation of the governing departmental circular and the principles of natural justice

2. Whether "absence from duties" constitutes a "serious complaint" or misconduct sufficient to warrant the maximum penalty of removal from service under the applicable guidelines

Article 226 of the Constitution of India regarding writ jurisdiction

Departmental Circular dated 10.07.2007, specifically Clause 3, which stipulates that in cases of "serious complaints" against an Anganwadi Worker, the Project Officer must examine an enquiry report before passing an order of removal or termination

Principle of Natural Justice, emphasizing the necessity of a fair hearing and the refutation of allegations before dismissal

The court found the termination to be mala fide, noting it appeared to be a retaliatory action for the petitioner’s participation in the Jansunwai (public hearing) before the Collector

It determined that the alleged resignation was legally invalid as it was unsigned and should not have been entertained by the authorities

The court held that the respondents failed to follow Clause 3 of the 2007 Circular, which mandates an inquiry for serious charges

The court reasoned that "absence from duties" does not constitute a "serious complaint" or grave misconduct

Given that Anganwadi Workers are women from rural backgrounds whose employment provides social and financial independence until age 60, the court held that the punishment of removal for a minor misconduct was disproportionate and lacked the procedural safeguard of an inquiry

It held that the termination was procedurally illegal and substantively unjustified

The court directed the respondents to reinstate the petitioner in service forthwith, though it declined to grant back wages