Supreme Court quashes High Court order, reinstates Anganwadi worker: Anjum Ara vs. State of Bihar (2024) INSC 40 (08 January 2024)

Date of the Judgment: 08 January 2024

Citation: (2024) INSC 40

Judges: B.R. Gavai, J. and Sandeep Mehta, J.

Can a High Court’s ruling striking down a guideline be ignored when deciding a case involving the same guideline? The Supreme Court of India recently addressed this question in a case concerning the appointment of an Anganwadi worker. The core issue revolves around whether an appointment can be cancelled based on a guideline that was later declared invalid by the High Court. This judgment highlights the importance of judicial pronouncements and their impact on administrative decisions. The bench consisted of Justice B.R. Gavai and Justice Sandeep Mehta, with the judgment authored by Justice B.R. Gavai.

Case Background

On 17th October 2012, the District Programme Officer, Katihar, issued a notice for the selection of Anganwadi workers. Anjum Ara, the appellant, and another candidate, respondent No. 8, applied for the position. Anjum Ara secured 80.60 marks, while respondent No. 8 secured 48.60 marks. Consequently, Anjum Ara was appointed as an Anganwadi Sevika on 2nd July 2013.

Respondent No. 8, dissatisfied with Anjum Ara’s appointment, filed a representation before the District Programme Officer, Katihar, seeking cancellation of Anjum Ara’s appointment and requesting her own appointment. This representation was rejected on 13th November 2014. Following this, respondent No. 8 appealed to the Appellate Authority, the Court of Joint Commissioner-cum-Secretary, Regional Transport Authority, Purnea. The Appellate Authority allowed the appeal on 30th July 2015, setting aside Anjum Ara’s appointment.

Aggrieved by the Appellate Authority’s decision, Anjum Ara filed a writ petition, CWJC No. 17585 of 2015, before the High Court of Judicature at Patna. The learned Single Judge dismissed the writ petition on 23rd August 2016. Anjum Ara then filed a Letters Patent Appeal (LPA) No. 1853 of 2016, which was also dismissed by the Division Bench of the High Court on 28th November 2022. Subsequently, Anjum Ara approached the Supreme Court.

Timeline

Course of Proceedings

The District Programme Officer, Katihar, initially rejected the representation of Respondent No. 8. Subsequently, the Appellate Authority overturned this decision, leading to the cancellation of Anjum Ara’s appointment. The High Court of Judicature at Patna upheld the Appellate Authority’s decision, first by the Single Judge and then by the Division Bench, which prompted the appeal to the Supreme Court.

Legal Framework

The case revolves around Clause 4.9 of the Anganwadi Sevika Guidelines, 2011 (“2011 Guidelines”). This clause imposed restrictions on the appointment of individuals whose family members were employed by the State Government or any State organization. The High Court of Judicature at Patna, in a separate case (CWJC No. 13210 of 2014), struck down this clause, finding it to be in violation of Articles 14 and 16 of the Constitution of India. Article 14 guarantees equality before the law, and Article 16 ensures equality of opportunity in matters of public employment.

Arguments

Appellant’s Arguments:

• The appellant argued that she was disqualified solely because her father was a Panchayat Teacher earning Rs. 6,000 per month.
• The appellant contended that Clause 4.9 of the 2011 Guidelines, which imposed the restriction, was already declared unconstitutional by the High Court in CWJC No. 13210 of 2014.
• The appellant submitted that once the High Court struck down Clause 4.9, it ceased to exist, and therefore, it was not necessary for the appellant to challenge it again.

Respondents’ Arguments:

• The respondents supported the High Court’s decision.
• They argued that the appellant did not challenge Clause 4.9 of the 2011 Guidelines before the High Court.

Submissions of Parties

Issues Framed by the Supreme Court

The Supreme Court did not explicitly frame issues in the judgment. However, the central issue was:

• Whether the High Court was correct in upholding the cancellation of the appellant’s appointment based on Clause 4.9 of the 2011 Guidelines, which had already been struck down by the same High Court.

Treatment of the Issue by the Court

Authorities

The Supreme Court considered the following authorities:

Judgment

How each authority was viewed by the Court?

• The High Court’s judgment in CWJC No. 13210 of 2014* was viewed as conclusive. The Supreme Court held that once the High Court struck down Clause 4.9 of the 2011 Guidelines, it ceased to exist, and therefore, it was not necessary for the appellant to challenge it again.

What weighed in the mind of the Court?

The Supreme Court’s decision was primarily influenced by the fact that the High Court had already struck down Clause 4.9 of the 2011 Guidelines. The Court emphasized that once a legal provision is declared invalid, it ceases to exist, and it is not necessary for individuals to challenge it again in subsequent cases. This principle of judicial consistency and the binding nature of High Court decisions were central to the Supreme Court’s reasoning.

Logical Reasoning:

The Court found that the High Court’s reasoning was unsustainable. The Supreme Court noted, “When the said Clause 4.9 of the 2011 Guidelines was struck down by the High Court vide judgment dated 27th September 2022, it ceased to exist.” The Court further stated, “As such, it was not necessary for the appellant to challenge the validity of the same inasmuch as the same was already held to be invalid by the very same High Court.” The Supreme Court concluded that “the judgments and orders passed by the learned Single Judge as well as the Division Bench are not sustainable in law.”

Key Takeaways

• When a High Court strikes down a legal provision, it ceases to exist, and individuals are not required to challenge it again in subsequent cases.
• Judicial consistency is crucial; lower courts must adhere to the rulings of higher courts.
• An appointment cannot be cancelled based on a guideline that has been declared invalid.
• The Supreme Court emphasized the importance of the binding nature of High Court decisions.

Directions

The Supreme Court issued the following directions:

• The appeal was allowed.
• The High Court’s judgments and orders were quashed and set aside.
• The writ petition and appeal filed by the appellant before the High Court were allowed.
• The order passed by the Appellate Authority was set aside.
• The appellant was directed to be reinstated forthwith.
• The appellant would not be entitled to wages for the period she was out of employment but would be entitled to continuity in service for all other purposes.

Development of Law

The ratio decidendi of this case is that once a High Court declares a legal provision invalid, it ceases to exist, and individuals are not required to challenge it again in subsequent cases. This judgment reinforces the principle of judicial consistency and the binding nature of High Court decisions. There is no change in the previous position of law, but the Supreme Court has reiterated the importance of adhering to judicial pronouncements.

Conclusion

The Supreme Court’s decision in Anjum Ara vs. The State of Bihar and Others underscores the significance of judicial consistency and the binding nature of High Court decisions. The Court held that once a legal provision is declared invalid, it ceases to exist, and it is not necessary for individuals to challenge it again in subsequent cases. The Supreme Court quashed the High Court’s order and directed the reinstatement of the appellant, emphasizing the importance of adhering to judicial pronouncements.