Supreme Court Denies Age Relaxation for Anganwadi Worker in Uttar Pradesh Recruitment Case

The Supreme Court of India, in State of Uttar Pradesh & Ors. v. Shanti Devi, ruled on a crucial issue related to the eligibility criteria for government recruitment. The case revolved around whether an Anganwadi worker could claim age relaxation under the Uttar Pradesh Public Services (Relaxation of Age Limits for Recruitment) Rules, 1992, for appointment to the post of Mukhya Sevika. The Supreme Court overturned the Allahabad High Court’s judgment, holding that the respondent was not entitled to age relaxation as a matter of right.

Background of the Case

The case originated from a recruitment process conducted under The Uttar Pradesh Child Development and Nutrition (Subordinate) Service Rules, 1992, which governs the appointment of Mukhya Sevika. The respondent, Shanti Devi, had served as an Anganwadi worker since 1987 and sought age relaxation to participate in the selection process. However, she had crossed the maximum age limit of 50 years prescribed under the rules.

Key developments in the case:

On January 9, 2018, a circular was issued for the selection of Mukhya Sevika candidates, requiring applicants to be below 50 years of age.
On March 12, 2018, Shanti Devi submitted a representation requesting age relaxation based on her continuous service as an Anganwadi worker.
Her request was denied by the District Program Officer, prompting her to file a writ petition before the Allahabad High Court.
The Single Judge of the High Court ruled in her favor, directing the authorities to consider her claim for age relaxation.
The State of Uttar Pradesh challenged the decision through a Special Appeal, which was dismissed by a Division Bench of the High Court.
Subsequently, the State government appealed to the Supreme Court.

Petitioners’ (State of Uttar Pradesh) Arguments

The State of Uttar Pradesh, represented by its legal counsel, made the following arguments:

The Uttar Pradesh Public Services (Relaxation of Age Limits for Recruitment) Rules, 1992, apply only to government employees, whereas Anganwadi workers are engaged under a state-run scheme and do not hold regular government posts.
The respondent’s case did not fall within the purview of Rule 3 of the Age Relaxation Rules of 1992.
The selection process had a uniform age criterion that was applied equally to all candidates, and granting individual relaxations would lead to arbitrary selections.
More than 70,000 eligible Anganwadi workers applied for 975 vacant posts, making uniformity in selection criteria essential.

Respondent’s Arguments

Shanti Devi defended the High Court’s ruling, arguing:

She had completed over three decades of service as an Anganwadi worker and should be granted age relaxation.
Her request was based on the Age Relaxation Rules of 1992, which allow relaxation in recruitment age limits at the discretion of the appointing authority.
The High Court correctly found that her case merited consideration under the 1992 Rules.

Supreme Court’s Key Observations

After reviewing the submissions, the Supreme Court made several key observations:

Definition of Government Employees: The Court held that Anganwadi workers are not government employees and therefore cannot claim benefits under the Age Relaxation Rules of 1992.
Discretionary Nature of Age Relaxation: The provision under Rule 3 of the Age Relaxation Rules of 1992 grants the Governor discretionary power to relax age limits but does not create an entitlement for candidates.
Uniformity in Recruitment Criteria: The Court emphasized that eligibility rules should be consistently applied to all applicants, ensuring fair selection.
Discretion of the Appointing Authority: Since the State authorities had already considered and rejected the respondent’s request twice (on October 3, 2018, and November 13, 2018), the High Court had no basis to intervene.

Supreme Court’s Judgment

Based on its findings, the Supreme Court ruled:

The appeal filed by the State of Uttar Pradesh was allowed.
The judgments of the Single Judge and the Division Bench of the Allahabad High Court were set aside.
Shanti Devi’s writ petition seeking age relaxation was dismissed.
The recruitment process would proceed based on the originally prescribed age criteria.

Impact of the Judgment

This ruling has significant implications for government recruitment policies:

Clarification on Anganwadi Workers’ Status: The Court reaffirmed that Anganwadi workers are not government employees and cannot claim benefits meant for regular government servants.
Preserving Uniformity in Recruitment: The decision ensures that recruitment processes are not altered on a case-by-case basis, maintaining fairness for all applicants.
Reaffirmation of Executive Discretion: The ruling confirms that age relaxation is a discretionary power of the government, not a vested right.
Guidance for Future Cases: The decision sets a precedent for handling similar disputes in recruitment policies across different states.

Conclusion

The Supreme Court’s ruling in State of Uttar Pradesh & Ors. v. Shanti Devi upholds the principles of fair recruitment and uniform application of eligibility criteria. By denying age relaxation for Anganwadi workers, the judgment reinforces the importance of procedural integrity in government job appointments. This decision will serve as a reference for future cases involving eligibility disputes in public sector recruitment.

Petitioner Name: State of Uttar Pradesh & Others.
Respondent Name: Shanti Devi.
Judgment By: Justice Dhananjaya Y Chandrachud, Justice A.S. Bopanna.
Place Of Incident: Uttar Pradesh.
Judgment Date: 08-08-2022.

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