The Telangana High Court has upheld the State government's decision to reserve the posts of Extension Officer Grade-I and Extension Officer Grade-II (Supervisors) in the Women Development and Child Welfare Department exclusively for women. The Court held that the policy was justified considering the nature of the beneficiaries and services under the Integrated Child Development Services (ICDS) scheme and found no reason to interfere with the government's decision.
Background of the Case
The petitions were filed by Boorla Mahesh and others, who challenged a 2013 amendment to G.O.Ms. No.14 that made only women candidates eligible for appointment as Extension Officers Grade-I and Grade-II by any method of recruitment. They also questioned recruitment notifications issued by the Telangana State Public Service Commission (TSPSC) in 2022 for these posts, contending that male candidates had been completely excluded from the selection process.
The petitioners argued that the original government order issued in 2000 contained no gender restriction and that the subsequent amendment violated Articles 14, 19(1)(g), and 21 of the Constitution. They also relied on Rule 22-A of the Telangana State and Subordinate Service Rules, 1996, which provides that preference to women should not result in the total exclusion of men from any category of posts.
Petitioners' Arguments
The petitioners submitted that the responsibilities of Extension Officers—including supervising Anganwadi Centres, training Anganwadi Workers, monitoring nutrition programmes, conducting inspections, and coordinating with Child Development Project Officers—could be performed by persons of any gender. Therefore, they argued that reserving 100% of the posts for women lacked a rational basis.
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They further relied on several judicial precedents to contend that complete reservation in favour of women had been disapproved in comparable situations and sought a fresh recruitment notification allowing candidates of all genders to compete.
State's Stand
The State government defended the policy, explaining that Extension Officers supervise Anganwadi Centres that primarily serve children, pregnant women, lactating mothers, and adolescent girls. The government argued that the service delivery system was designed keeping in mind the sensitivity of these beneficiaries and the fact that Anganwadi workers themselves are women.
The government also maintained that the reservation policy was a conscious administrative decision intended to ensure an appropriate and safe working environment for field-level services under the Women Development and Child Welfare Department. TSPSC submitted that it had merely implemented the eligibility conditions prescribed by the government.
Court's Observations
Justice T. Madhavi Devi noted that although the original 2000 government order did not prescribe any gender-based reservation, the government was competent to amend the guidelines in 2013 after assessing the requirements of the posts.
The Court observed that while the duties listed for Extension Officers did not, by themselves, show that only women could discharge those functions, the broader context of the scheme was significant.
Referring to the nature of the ICDS programme, the Court observed that
"the stake holders or the beneficiaries of the scheme are children, adolescent and young girls, pregnant women and lactating mothers" and that "all the stake holders as well as the primary functionaries are women."
In these circumstances, the government's decision to reserve the posts exclusively for women could not be termed arbitrary.
The Court also relied on the Supreme Court's decision in Vijay Lakshmi v. Punjab University, observing that
"the policy decision of the Government as a preventive or precautionary measure cannot be interfered with by the Courts."
It held that Article 15(3) of the Constitution permits the State to make special provisions for women and that such classification was justified in the present case.
At the same time, the Court distinguished the judgments cited by the petitioners, observing that those decisions related to different factual situations, including appointments to Family Courts and medical specialist posts, and therefore did not govern the present dispute.
Decision
Finding that the government's policy decision was based on the nature of the services provided and the profile of the beneficiaries under the Women Development and Child Welfare Department, the Telangana High Court dismissed both writ petitions. It upheld the validity of the 2013 amendment reserving the posts of Extension Officer Grade-I and Grade-II exclusively for women and declined to interfere with the recruitment notifications issued pursuant to that policy. No order as to costs was passed.
Case Details:
Case Title: Boorla Mahesh & Ors. v. State of Telangana & Ors.
Case Number: W.P. No. 37458 of 2022 and W.P. No. 37535 of 2022
Judge: Justice T. Madhavi Devi
Decision Date: 30 June 2026
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