Atul Nandu Jadhav vs the State of Maharashtra Thru. G.P. and Ors. — Bombay HC (2026) — LawSathi Research

Atul Nandu Jadhav vs the State of Maharashtra Thru. G.P. and Ors. — Bombay HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Impugned order of 04-09-2025 quashed and set aside; proposals restored to the file of the Education Officer (secondary), Pune, Zilla Parishad for detailed inquiry and reasoned reconsideration in light of Bhairavnath Charitable Trust (WP/11391/2024) paragraphs 5 and 6 and factors (a)-(e), within 60 days for the exercise and 30 days thereafter for the reasoned order, communication preferably by email with contesting Respondents tendering email addresses; the Writ Petitions were thereafter disposed of in the above terms.

Issue for consideration

Whether the impugned order dated 04-09-2025 rejecting the proposal for 20% Grant-in-Aid - practically a single-sentence remark-column order carrying no reasons (issued amid record aspects that created an impression of bogus appointments) - should be interfered with so that each case receives a detailed inquiry and a subjective assessment culminating in a reasoned order. +1 more

Court's answer

The Education Officer had practically passed a single sentence order under the remarks column; had the impugned order been a reasoned one, it would have indicated that the concerned Authority had applied its mind and had appropriately assessed the proposals of each of the Petitioners - for this reason the Court was required to set the impugned order aside.

Ratio / Principle

The Writ Petition is partly allowed: the impugned order is quashed and set aside, and the proposals of these Petitioners are restored to the file of the Education Officer (secondary), Pune, Zilla Parishad.

Key takeaways

The Education Officer is expected to reconsider the proposals of these Petitioners by adverting to the view taken by the Court in the reproduced paragraphs 5 and 6 of the Bhairavnath Charitable Trust order (approval once legally granted cannot be cancelled save on noticed glaring fraud; verification of approvals, statements from the Education Officers who signed the camp approval orders, and opportunity of personal hearing to the management and concerned employees).ratio¶¶48
While passing an order on the proposals tendered by the Management, the Education Officer shall consider: (a) whether the procedure required for carrying out selection or appointment was followed by the Management; (b) whether the advertisement was published in largely circulated newspapers; (c) whether a legally constituted Selection Committee conducted interviews of all candidates including these Petitioners; (d) on subjective assessment, whether the Management has records indicating a proper selection process was followed in selecting and appointing the Petitioners; and (e) on noticing any infirmities or deficiencies, pass a reasoned order on each of the proposals of these three Petitioners.ratio

Detailed headnote1 paragraphs

Bombay High Court (Civil Appellate Jurisdiction), Ravindra V. Ghuge & Abhay J. Mantri JJ., 12-01-2026 - Civil Writ Petition No. 13660 of 2025 (Balasaheb Shivaji Devmunde), with Nos. 13700 of 2025 (Atul Nandu Jadhav) and 16433 of 2025 (Vaibhav Shriram Kopapkar) v. State of Maharashtra & ors.: By an unreasoned order dated 04-09-2025, the proposal for 20% Grant-in-Aid (sanctioned 25-04-2023 effective 01-01-2023) was rejected solely on a remark-column notation that the Petitioners' appointment approvals did not appear in the outward register and the approval orders were untraceable. Holding that the Education Officer had practically passed a single sentence order under the remarks column, and that a reasoned order would have shown application of mind and appropriate assessment of each proposal, the Court quashed and set aside the impugned order, partly allowed the petitions, and restored the proposals to the Education Officer (secondary), Pune, Zilla Parishad. The Education Officer was directed to reconsider the proposals by adverting to paragraphs 5 and 6 of the Court's order dated 11-09-2025 in WP/11391/2024 (Bhairavnath Charitable Trust) - which reproduced the Aurangabad Division Bench conclusion in Pramod Prabhakar Pokale that a legally granted approval cannot be cancelled except where glaring fraud is noticed, and requires verification of approvals, statements by the Education Officers who signed camp approval orders, and personal hearings - and to assess: adherence to selection/appointment procedure, publication of advertisement in largely circulated newspapers, conduct of interviews by a legally constituted Selection Committee, management records evidencing proper selection, and issue of a reasoned order on each proposal where infirmities are noticed; exercise preferably within 60 days, reasoned order within 30 days thereafter, communication preferably by email with contesting Respondents tendering email addresses. Writ Petitions disposed of in these terms.