Suvarna Sampat Patil vs the State of Maharashtra through the Secretary and Ors. — Bombay HC (2025) — LawSathi Research

Suvarna Sampat Patil vs the State of Maharashtra through the Secretary and Ors. — Bombay HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

Interim/procedural directions only: (i) attendance verification for 09.10.2025 and 23.09.2025; (ii) show-cause notices with 7-day written explanations, failing justification one day's salary deductible; (iii) managements to tender ready-reference charts in four categories with writ petition numbers and petitioner names; (iv) last opportunity until 06.11.2025 to serve copies of rejection-of-approval orders; (v) matters adjourned to 12.11.2025 at 3.00 p.m.; (vi) disposed MPSC petitions (WP Nos. 10724, 10721, 10726 of 2023) confined to records.

Issue for consideration

Resolution of the dispute, still unresolved between the Management and the employee-teachers, concerning the status/entitlement of teachers appointed prior to this Court's judgment in PIL No. 8 of 2015 — including appointees on clock-hour basis and teachers working without approval (after introduction of the Pavitra Portal) on aided and un-aided establishments.

Court's answer

All matters are adjourned as there is, at this stage, no meeting of minds between the Management and the employees; the Management is called upon to furnish ready-reference charts covering (a) petitioners and similarly placed employees appointed prior to this Court's judgment in PIL No. 8 of 2015, (b) teachers appointed prior to that judgment on clock-hour basis, (c) teachers appointed prior to the judgment, including via the Pavitra Portal, presently working on aided establishments without approval, and (d) a separate list for un-aided establishments — each chart bearing the writ petition number and petitioner's name.

Ratio / Principle

Managements shall verify from attendance sheets how many teachers were absent from their institutions and teaching curriculum on 09.10.2025 and 23.09.2025; the Court permits managements to issue show-cause notices to teachers who attended Court, and after receiving written explanations within 7 days, to deduct one day's salary where the absence had no justification — to prevent large-scale absenteeism caused by teachers travelling to Mumbai for court hearings.

Key takeaways

As a last chance, any candidate inadvertently not served with the rejection-of-approval order may be served until 6 November 2025.ratio¶¶107
Writ Petition Nos. 10724, 10721 and 10726 of 2023 (MPSC matters), having already been disposed of on 20 January 2025, their files shall be confined to the records.ratio¶¶109

Detailed headnote1 paragraphs

Bombay High Court (Ghuge & Bhobe, JJ.), order dated 09.10.2025 in a large consolidated batch of writ petitions led by WP No. 3145 of 2022 (Smt. Ashwini Vithhal Jadhav) against the State of Maharashtra, School Education Department, concerning teachers appointed prior to this Court's judgment in PIL No. 8 of 2015 — including clock-hour-basis appointees and teachers working without approval (post-Pavitra Portal) on aided and un-aided establishments. Interim directions: managements to verify attendance for 09.10.2025 and 23.09.2025 and, after show-cause notices and written explanations within 7 days, deduct one day's salary of teachers absent without justification, the Court being 'compelled' to curb large-scale absenteeism arising from teachers attending hearings in Mumbai; managements to file ready-reference charts (writ-petition-wise, petitioner-wise) in four categories; a chart dated 09.10.2025 taken on record and marked 'X-1'; last chance till 06.11.2025 for serving rejection-of-approval orders (earlier supplied via WhatsApp pursuant to orders of 21.04.2025, with costs imposed on 30.06.2025 for default); matters adjourned to 12.11.2025, 3.00 p.m., there being no meeting of minds between management and employees; MPSC-related WP Nos. 10724, 10721 and 10726 of 2023, already disposed on 20.01.2025, confined to records.

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Digitally signed GAYATRI by GAYATRIRAJENDRA RAJENDRASHIMPI SHIMPIDate:2025.10.13 18:57:33 +0530

IN THE HIGH COURT OF JUDICATURE AT BOMBAY CIVIL APPELLATE JURISDICTION

(Sr. No. 901) WRIT PETITION NO. 3145 OF 2022

Smt. Ashwini Vithhal Jadhav … Petitioner Versus The State Of Maharashtra Thr. Secretary School Education Dept. And Ors … Respondents WITH (Sr. No. 902) WRIT PETITION NO. 12921 OF 2023 Appasaheb Rangnath Kedar & Ors. … Petitioners Versus State Of Maha. Thr. Sec. School Education Dept. And Ors. … Respondents WITH (Sr. No. 903) WRIT PETITION NO. 1824 OF 2024 Smt. Vandana Balasaheb Auti … Petitioner Versus State Of Maha. Thr. Sec. School Education Dept. And Ors. … Respondents WITH (Sr. No. 904) WRIT PETITION NO. 1827 OF 2024 Smt. Vijaya vilas dhaigude … Petitioner Versus State Of Maha. Thr. Sec. School Finance Dept. And Ors. … Respondents WITH (Sr. No. 905) WRIT PETITION NO. 5476 OF 2025 Suvarna Sampat Patil … Petitioner Versus

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The State of Maharashtra Through The Secretary And Ors. … Respondents

WITH (Sr. No. 906) WRIT PETITION NO. 8015 OF 2025

Vidya Murlidhar Mohite … Petitioner Versus The State of Maharashtra Throu. Its Sec. School Education Dept And Ors … Respondents

WITH (Sr. No. 01) WRIT PETITION NO. 2177 OF 2022 WITH WRIT PETITION NO. 460 OF 2022

Randhave Sanjit Ankush And Ors. … Petitioners Versus The State Of Maharashtra Through Its Secretary, Dept. Of School Edu. And Sports And Ors. … Respondents

WITH

(Sr. No. 02) WRIT PETITION NO. 12190 OF 2023

Rajaram Shivaji Thorat … petitioners Versus The State Of Mahahrashtra Thr The Secretary School Education Dept. And Anr … Respondents

WITH WRIT PETITION (ST) NO. 90 OF 2022 WITH WRIT PETITION NO. 15471 OF 2024 WITH WRIT PETITION (ST) NO. 1282 OF 2022 WITH WRIT PETITION (ST) NO.1284 OF 2022 WITH

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WRIT PETITION (ST) NO.1290 OF 2022 WITH WRIT PETITION NO. 4839 OF 2022 WITH WRIT PETITION (ST) NO.1313 OF 2022 WITH WRIT PETITION NO.4837 OF 2022 WITH WRIT PETITION (ST) NO.1352 OF 2022 WITH WRIT PETITION (ST) NO.1357 OF 2022 WITH WRIT PETITION NO. 3454 OF 2022 WITH WRIT PETITION NO. 3455 OF 2022 WITH WRIT PETITION NO. 2199 OF 2025 WITH WRIT PETITION NO. 2190 OF 2025 WITH WRIT PETITION (ST) NO. 3654 OF 2024 WITH WRIT PETITION NO. 5252 OF 2025 WITH WRIT PETITION NO. 5255 OF 2025 WITH WRIT PETITION NO. 3360 OF 2024 WITH WRIT PETITION NO. 3356 OF 2024 WITH WRIT PETITION NO. 3355 OF 2024 WITH WRIT PETITION NO. 5304 OF 2024 WITH WRIT PETITION NO. 5305 OF 2024 WITH WRIT PETITION NO. 3366 OF 2024 WITH WRIT PETITION NO. 4719 OF 2025 WITH WRIT PETITION NO. 12654 OF 2024

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WITH WRIT PETITION NO. 9752 OF 2024 WITH WRIT PETITION NO. 5243 OF 2025 WITH WRIT PETITION NO.5247 OF 2025 WITH WRIT PETITION NO.9772 OF 2022 WITH WRIT PETITION NO.9770 OF 2022 WITH WRIT PETITION NO.9781 OF 2022 WITH WRIT PETITION NO.9776 OF 2022 WITH WRIT PETITION NO.12800 OF 2022 WITH WRIT PETITION NO.9778 OF 2022 WITH WRIT PETITION (ST) NO.13935 OF 2025 WITH WRIT PETITION (ST) NO. 13937 OF 2025 WITH WRIT PETITION NO. 12653 OF 2024 WITH WRIT PETITION NO.12656 OF 2024 WITH WRIT PETITION NO.12638 OF 2024 WITH WRIT PETITION NO. 12655 OF 2024 WITH WRIT PETITION NO. 7457 OF 2025 WITH WRIT PETITION NO. 8760 OF 2025 WITH WRIT PETITION NO. 8761 OF 2025 WITH WRIT PETITION NO.5280 OF 2025 WITH WRIT PETITION NO. 7810 OF 2025 WITH

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WRIT PETITION NO. 8759 OF 2025 WITH WRIT PETITION NO. 8757 OF 2025 WITH WRIT PETITION NO. 1522 OF 2024 WITH WRIT PETITION (ST) NO. 19189 OF 2024 WITH WRIT PETITION NO. 12413 OF 2022 WITH WRIT PETITION NO. 16159 OF 2024 WITH WRIT PETITION NO. 10724 OF 2023 WITH WRIT PETITION NO. 10721 OF 2023 WITH WRIT PETITION NO. 10726 OF 2023 WITH WRIT PETITION NO. 11997 OF 2024 WITH WRIT PETITION NO. 1836 OF 2024 WITH INTERIM APPLICATION NO. 1516 OF 2024 WITH INTERIM APPLICATION NO. 11185 OF 2024 WITH WRIT PETITION NO. 10798 OF 2024 WITH INTERIM APPLICATION NO. 11187 OF 2024 WITH INTERIM APPLICATION NO. 11188 OF 2024 WITH WRIT PETITION NO. 10800 OF 2024 WITH WRIT PETITION NO. 10799 OF 2024 WITH WRIT PETITION NO. 10802 OF 2024 WITH WRIT PETITION NO. 10801 OF 2024 WITH INTERIM APPLICATION NO. 11195 OF 2024

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WITH

INTERIM APPLICATION NO. 11199 OF 2024 WITH INTERIM APPLICATION NO. 11200 OF 2024 WITH INTERIM APPLICATION NO. 11202 OF 2024 WITH WRIT PETITION NO. 12191 OF 2023 WITH WRIT PETITION NO. 12188 OF 2023 WITH WRIT PETITION NO. 12189 OF 2023 WITH WRIT PETITION NO. 1837 OF 2024 WITH WRIT PETITION NO. 11636 OF 2024 WITH WRIT PETITION NO. 11649 OF 2024 WITH WRIT PETITION NO. 1838 OF 2024 WITH INTERIM APPLICATION NO. 1514 OF 2024 WITH WRIT PETITION NO. 15830 OF 2024 WITH WRIT PETITION NO. 5011 OF 2024 WITH WRIT PETITION NO. 18366 OF 2024 WITH WRIT PETITION NO. 9648 OF 2022 WITH WRIT PETITION NO. 16363 OF 2024 WITH WRIT PETITION NO. 12328 OF 2025 WITH WRIT PETITION NO. 12330 OF 2025 WITH WRIT PETITION NO. 12349 OF 2025 WITH WRIT PETITION NO. 12348 OF 2025 WITH

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WRIT PETITION NO. 1839 OF 2024 WITH WRIT PETITION NO. 16721 OF 2024 WITH WRIT PETITION NO. 17722 OF 2024 WITH WRIT PETITION NO. 5331 OF 2021 WITH WRIT PETITION NO. 17779 OF 2024 WITH WRIT PETITION NO. 7102 OF 2024 WITH WRIT PETITION NO. 2133 OF 2024 WITH WRIT PETITION NO. 8755 OF 2025 WITH WRIT PETITION NO. 2132 OF 2024 WITH WRIT PETITION NO. 2112 OF 2024 WITH WRIT PETITION NO. 18203 OF 2024 WITH WRIT PETITION NO. 2142 OF 2024 WITH WRIT PETITION NO. 2138 OF 2024 WITH WRIT PETITION NO. 1844 OF 2024 WITH WRIT PETITION NO. 2140 OF 2024 WITH WRIT PETITION NO. 2141 OF 2024 WITH WRIT PETITION NO. 2143 OF 2024 WITH WRIT PETITION NO. 17780 OF 2024 WITH WRIT PETITION NO. 16775 OF 2023 WITH INTERIM APPLICATION (ST) NO. 34058 OF 2024 IN WRIT PETITION NO. 16776 OF 2023

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WITH

INTERIM APPLICATION (ST) NO. 33914 OF 2024 IN WRIT PETITION NO. 16777 OF 2023 WITH

WRIT PETITION NO. 16780 OF 2023 WITH WRIT PETITION NO. 16785 OF 2023 WITH WRIT PETITION NO. 16791 OF 2023 WITH WRIT PETITION NO. 18611 OF 2024 WITH WRIT PETITION NO. 18862 OF 2024 WITH WRIT PETITION (ST) NO. 36879 OF 2024 WITH WRIT PETITION NO. 19545 OF 2024

WITH (Sr. No. 03) WRIT PETITION NO. 8763 OF 2025

Vikas Hari Kumbhar … Petitioners Versus The Sate of Maharashtra Thor. Its Principal Secretary School Education And Sport Department … Respondents

WITH

(Sr. No. 04) WRIT PETITION NO. 9956 OF 2025

Pallavi Maheshkumar Shinde … Petitioners Versus The State Of Maharashtra Thor. The Secretary School Education Dept. … Respondents

WITH (Sr. No. 05) WRIT PETITION NO. 9986 OF 2025

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Barge Swapnali Murlidhar And Anr. … Petitioners Versus The State of Maharashtra Through Its Secretary And Anr. … Respondents ****

Mr. N. V. Bandiwadekar, Senior Advocate a/w Mr. Vinayak Kumbar, Mr. Rajendra Khaire i/b Ms. Ashwini Bandiwadekar, Advocates for Petitioner.

Mr. A. A. Kumbhakoni, Senior Advocate i/b Mr. Akshay P. Shinde, Advocates for Respondent No.4 in WP No. 16775 of 2023.

Mr. Rohit Parab, Advocate for Applicant in IA (ST) No. 34058 of 2024 & IA (ST) No. 33914/2024.

Mr. Sharad T. Bhosale i/b Mr. Dilip Bodake, Advocates for Petitioner in Sr. No.2.

Mr. Sharad T. Bhosale, Advocate for Petitioner in WP Nos. 2190 of 2025 and WP No. 2199 of 2025.

Mr. Rajat Shimpi i/b Mr. Satyajeet Rajeshirke, Advocates for Petitioner in Sr. Nos.901 & 905 and Sr. No.2.

Mr. Nitin Gaware-Patil, Advocate for Petitioner in Sr. No.2.

Mr. Ramchandra Wagh i/b Mr. Vijay B. Jagtap, Advocates for Petitioner in WP Nos. 11636 of 2024, 11649 of 2024 & 16786 of 2023.

Mr. Mahesh Deshmukh a/w Mr. Sandeep Gupta i/b Mr. A. G. Ambetkar, Advocates for Petitioner in Sr. Nos. 902 to 904 and 906.

Mr. Sukand R. Kulkarni i/b Mr. Abhijit A. Devkhile, Advocates for Petitioner in Sr. Nos. 1 and Sr. No. 5.

Mr. Mihir Desai Senior Advocate a/w Mr. Pradeep Yadav i/b Mr. Saumitra Salunke, Advocates for Petitioner in WP No. 11997 of 2024.

Mr. Pradeep Yadav for Petitioners in WP Nos. 18203 of 2024, WP No. 3360 of 2024, WP No. 3355/2024, WP No. 3366 of 2024, WP No. 12654 of 2024, WP No.12656 of 2024, WP No. 17779 of 2024, WP No. 2112 of 2024, WP No. 2138 of 2024, WP No. 2140 of 2024, WP No. 2141 of 2024, WP No. 2143 of 2024, WP No. 17780 of 2024, WP No. 18611 of

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2024, WP No. 4719 of 2025, WP No. 5243 of 2025, WP No. 8757 of 2025, WP No. 8760 of 2025, WP No. 8761 of 2025, WP No. 7457 of 2025 WP No. 8755 of 2025, WP No. 15741 of 2024, WP No. 7810 of 2025 and WP No. 8759 of 2025.

Mr. Saumitra Salunke, Advocate for Petitioner in WP No. 2142 of 2024 i/b Mr. Pradeep Yadav in WP No. 12638 of 2024.

Ms. Swapnali Chavan, Advocate for Petitioners in WP No. 12653 of 2024, WP No. 12655 of 2024, WP No. 2133 of 2024, WP No. 2132/2024.

Mr. Pradeep Yadav, Advocate for Petitioners in WP No. 9956 of 2025.

Mr. B. V. Samant, Addl GP (1 to 118), with, Smt. P. M. Joshi Deshpande, AGP, Mr. B. V. Samant Additional GP, Mr. S. H. Kankal, AGP, Mr. A. K. Naik AGP, Ms. Priyanka Chavan AGP, Mr. V. G. Badgujar, AGP, Smt. P. N. Diwan, AGP, Mr. A. C. Bhadang, AGP.

CORAM : RAVINDRA V. GHUGE AND ASHWIN D. BHOBE, JJ.

DATE : 9^th OCTOBER, 2025

P.C. :

The Managements in which these Petitioners are working

shall verify from their attendance sheets as to how many teachers were absent from their institutions and the teaching curriculum, today on 9^th October, 2025, as well as on 23^rd September, 2025.

On 23^rd September, 2025, a huge number of teachers were

present in the Court Hall and the learned Senior Advocate Shri

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Kumbhakoni rightly pointed out to all our queries that these are those Petitioners, who have skipped their classes and come to the Court on 23^rd September, 2025. On that date, we orally stated that the Management should proceed to deduct their one-day salary. Today, the Court Room is filled with teachers in large numbers. Hence, we permit the Management to issue them show cause notices and after receiving their written explanations within 7 days, in cases wherein teachers have no justification for their absence and it is noticed that they had attended the Court proceedings today, their salary would be deducted. We are compelled to pass this order since we do not want the Schools and Educational Institutions to have large-scale absenteeism of the teachers only because they have come to Mumbai to hear their lawyers address the Court.

All these matters are getting adjourned today as there is no meeting of minds at this stage, between the Management and the employees. We call upon the Management to give us ready reference charts / data as under :-

(a) All such teachers, who are the Petitioners before us as well as similarly placed employees, who have not approached the High Court and who have been appointed prior to the Judgment of this Court in PIL

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No. 8 of 2015 Judgment dated 2416 of 2025.

(b) All such teachers who have been appointed prior to the above-

stated Judgment of this Court, on clock-hour basis.

(c) List of teachers, who were appointed prior to the Judgment, including (the Pavitra Portal), and are presently working on aided establishments, without approval.

(d) A separate list of teachers, who have also been appointed prior to the Judgment, introducing the Pavitra Portal, on un-aided establishments.

The ready reference charts as indicated above shall include the number of the Writ Petition and the names of the Petitioner.

We make it clear that should this be taken on record.

The learned Senior Advocate Shri Kumbhakoni appearing

for the Management has tendered a ready reference chart (one page) dated 09^th October, 2025 which is taken on record and marked as ‘X-1 ’ for identification.

Let such charts be prepared by the Management and be

tendered to the Court.

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Pursuant to one of our earlier orders dated 21^st April, 2025 by which we directed the Education Authorities to supply copies of orders of rejection of approval to the concerned candidates. The learned Additional GP submits that such orders have been supplied through WhatsApp. A further order was also passed on 30^th June, 2025 imposing of costs for non supply of copy of rejection order.

As a last chance, in the event anybody is inadvertently not served with the order, the time available from today until 6^th November, 2025 shall be utilized for serving copies of the said order on those persons, who may not have been supplied.

List all these matters on 12^th November, 2025 at 3.00 p.m

Writ Petition Nos. 10724 of 2023, 10721 of 2023 and 10726 of 2023 pertain to the MPSC and which have already been disposed off on 20^th January, 2025. As such, these files shall be confined to the records.

(ASHWIN D. BHOBE, J.) (RAVINDRA V. GHUGE, J.)

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