Termination upheld where show-cause notice, enquiry, and opportunity to explain satisfied natural justice.

The petitioner was appointed as an Anganwadi Worker on 01.03.2003 and served until 2024. She was issued a show-cause notice dated 26.12.2024 alleging that she had demanded and accepted ₹150 from Tanu Yadav/Aman Yadav for processing an online application under the Pradhan Mantri Matra Vandana Scheme, despite the scheme requiring no charge from beneficiaries.

The petitioner denied the allegation and asserted that the complainant’s husband bore animosity towards her due to a land dispute. She also contended that she was not afforded an opportunity to substantiate her defence by leading evidence.

Following an enquiry, the disciplinary authority terminated her services by order dated 09.01.2025. The termination was affirmed in appellate proceedings, including by order dated 30.01.2026.

The petitioner challenged the orders under Article 226 of the Constitution, seeking reinstatement and consequential benefits, particularly as she had crossed the age of superannuation.

Whether the disciplinary authorities complied with the procedure prescribed under the scheme/circular dated 10.07.2007 governing disciplinary action against Anganwadi Workers.

Whether the petitioner was denied the principles of natural justice by not being afforded a proper opportunity to substantiate her defence.

Whether the orders terminating the petitioner’s services and affirming such termination warranted interference in judicial review, notwithstanding the petitioner’s admission that she had received ₹150.

The Court applied the disciplinary procedure prescribed under the scheme/circular dated 10.07.2007 for Anganwadi Workers.

It further applied the principles of natural justice, particularly the requirement that the delinquent employee receive notice of the allegations and a meaningful opportunity to explain them before disciplinary action is imposed.

In judicial review of disciplinary proceedings, the Court’s examination is limited primarily to whether the prescribed procedure and principles of natural justice were followed; it does not ordinarily reappreciate the factual findings where the disciplinary authorities have acted within jurisdiction.

The Court also applied the governing principle under the Pradhan Mantri Matra Vandana Scheme that no fee or charge was payable by beneficiaries for processing their applications.

The Court found that the petitioner had been served with a show-cause notice, an enquiry had been conducted, and statements had been recorded in note-sheets dated 02.01.2025 and 09.01.2025.

During the proceedings, the petitioner acknowledged receiving ₹150 but attempted to justify it as payment to an MP Online operator because she could not process the application herself.

Since the scheme did not authorise collection of any amount from applicants or beneficiaries, and the petitioner produced no document permitting such collection, the Court treated the receipt of the money as unauthorised and illegal gratification.

The Court held that the enquiry and subsequent orders afforded the petitioner an adequate opportunity to explain the allegation and that the disciplinary and appellate authorities had passed reasoned orders. Consequently, no breach of the prescribed procedure or natural justice was established.

The writ petition was dismissed, and the orders terminating the petitioner’s services and affirming the termination were left undisturbed. No reinstatement or consequential benefits were granted.