The Indore Bench of the Madhya Pradesh High Court has quashed the reinstatement of a retired Anganwadi Sahayika, holding that Aadhaar and voter ID cards cannot be used to reopen settled service records after retirement. The court restored the appointment of another woman who had lawfully filled the vacant post and ordered recovery of salary wrongly paid for years after superannuation.
Background of the Case
The case arose from a dispute over the post of Anganwadi Sahayika at Jamli (Ambapura) centre in Dhar district. Pramila, the petitioner, was appointed in June 2018 after a proper selection process conducted by the Women and Child Development Department. She joined duty and continued to work without any complaint.
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Before her appointment, the same post was held by Hirlibai (respondent No.5), whose date of birth in official service records was recorded as 5 March 1955. Based on this entry, she was retired on attaining the age of 62 on 5 March 2017. The retirement order was never challenged at that time.
Nearly two years later, Hirlibai approached the Additional Collector, Dhar, claiming that her date of birth had been wrongly entered and that she was actually born on 1 January 1964. Her appeal relied solely on entries in her Aadhaar card and voter identity card. The appellate authority allowed her appeal in September 2020 without issuing notice to Pramila, who was already working on the post. A consequential order followed, reinstating Hirlibai and removing Pramila from service.
Arguments Before the Court
Pramila challenged both orders before the High Court. Her counsel argued that the appeal itself was barred by delay and that service records cannot be altered after retirement. It was also submitted that Aadhaar and voter ID cards are not conclusive proof of date of birth in service matters. Most importantly, the petitioner contended that she was removed from service without being heard, in clear violation of natural justice.
The State defended the orders by stating that once the retirement order of Hirlibai was set aside, the department had no option but to reinstate her, as there was only one sanctioned post at the centre.
Court’s Observations
Justice Jai Kumar Pillai found serious flaws in the appellate process. The court noted that Hirlibai had accepted her recorded date of birth throughout her service and even at the time of retirement. Allowing her to reopen the issue after superannuation, the court said, was legally impermissible.
“The relationship of employer and employee comes to an end after retirement,” the bench observed, adding that reopening settled service issues causes administrative uncertainty and harms third parties who have already been appointed lawfully.
The court was particularly critical of reliance on Aadhaar and voter ID cards. Citing Supreme Court and High Court precedents, it held that these documents are meant for identification and are often based on self-declaration.
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“They cannot override official service records maintained by the employer,” the judge noted.
The court also found the claim of a 1964 birth year implausible, pointing out that Hirlibai’s son and daughter-in-law had recorded birth years of 1959 and 1960, respectively.
Equally serious was the failure to hear Pramila. The bench stressed that any order resulting in termination of service has civil consequences and must follow the principle of hearing the affected person. Deciding the appeal behind her back, the court said, struck at the root of fair procedure.
Final Decision
Allowing the writ petition, the High Court quashed both the appellate order dated 1 September 2020 and the consequential termination order dated 21 November 2020. The court directed the authorities to reinstate Pramila as Anganwadi Sahayika with continuity of service and all consequential benefits.
The court further ordered recovery of the entire salary and monetary benefits paid to Hirlibai after her retirement in March 2017, along with 6% annual interest, to be deposited with the State exchequer within 60 days.
Case Title: Pramila v. State of Madhya Pradesh & Others
Case Number: Writ Petition No. 19295 of 2020
Date Pronounced: 13 January 2026
