Madhya Pradesh High Court Quashes Reinstatement of Retired Anganwadi Worker Court Orders Reinstatement of Petitioner, Emphasizes Importance of Official Service Records and Natural Justice
Indore, January 13, 2026 - The Madhya Pradesh High Court has set aside the reinstatement order of a retired Anganwadi worker, emphasizing the presumption of correctness attached to official service records and the violation of principles of natural justice. The decision came as a relief to Pramila, who had been removed from her position as Anganwadi Sahayika following an appellate order favoring Respondent No. 5, Hirlibai, based on a claim of incorrect date of birth.
The case arose from an appeal filed by Hirlibai nearly two years post-retirement, claiming her date of birth was incorrectly recorded as March 5, 1955, instead of January 1, 1964. The appeal relied solely on entries in her Aadhaar Card and Voter Identity Card. Despite the significant delay and questionable evidentiary value of the documents, the Additional Collector, District Dhar, allowed the appeal, reinstating Hirlibai and consequently terminating Pramila's services.
Justice Jai Kumar Pillai, presiding over the case, highlighted several critical legal principles, including the presumption of correctness of service records and the doctrine of delay and laches. The court noted that an employee's acceptance of the recorded date of birth during service precludes challenges post-retirement, as it disrupts administrative stability and justice to third parties.
The judgment also scrutinized the reliance on Aadhaar and Voter ID cards as determinative proof of date of birth. Citing Supreme Court and High Court precedents, the court underscored that such documents, based on self-declaration, lack the evidentiary sanctity to override official records.
Crucially, the court found that the appellate process violated natural justice principles. Pramila was neither impleaded as a necessary party nor afforded a hearing, despite being directly affected by the appellate order. This omission rendered the order void, emphasizing the requirement for fairness in administrative decisions impacting civil rights.
The court quashed both the appellate order of September 1, 2020, and the consequential termination order, directing the reinstatement of Pramila with continuity of service and all associated benefits. Additionally, the court ordered the recovery of salary paid to Hirlibai post-retirement, underscoring the legal and financial accountability for undue benefits.
The ruling reinforces the sanctity of official service records and procedural fairness, setting a significant precedent for service jurisprudence and administrative decision-making.
Bottom Line:
Date of birth recorded in official service records enjoys a presumption of correctness - Challenge to such entry must be raised at the earliest with unimpeachable evidence. Aadhaar Card and Voter Identity Card cannot be treated as determinative proof of date of birth in service matters.
Statutory provision(s): Articles 226 of the Constitution of India, Principles of Natural Justice, Service Law Principles
Pramila v. State of Madhya Pradesh, (Madhya Pradesh)(Indore) : Law Finder Doc Id # 2837468
