Dismissed¶53

Smt. Rajkumari Baiga v. State of Chhattisgarh

Chhattisgarh HC5 Apr 2026WPS/4923/2023

Case brief

AI extract

What is this about?

Locus standi; writ jurisdiction; person aggrieved; direct and substantial interest; invocation of extraordinary jurisdiction; Anganwadi Worker appointment; Janpad Panchayat Bharatpur; General Administration Committee; Guidelines dated 02/04/2008; quo warranto; appointment orders dated 19/05/2023; Chhattisgarh High Court Bilaspur; petition dismissed for want of standing.

What did the court decide?

Only a person aggrieved, having a direct and substantial interest in the matter, is entitled to invoke the writ jurisdiction of the Court; the petitioner does not possess the requisite locus standi to challenge the appointments of respondent Nos. 7 to 14 or to seek quashment of the order dated 19.05.2023. ¶52

Smt. Rajkumari Baiga Vs State of Chhattisgarh — Chhattisgarh HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

¶53

Issue for consideration

Whether the petitioner, Chairman of the General Administration Committee of Janpad Panchayat Bharatpur, possesses locus standi to challenge the appointments of respondent Nos. 7 to 14 and to seek quashment of the order dated 19.05.2023. +1 more

¶52

Court's answer

¶52

Ratio / Principle

The writ petition is dismissed solely on the ground that the petitioner lacks the requisite locus standi, no enforceable or individual legal right of the petitioner being demonstrated to have been infringed or adversely affected; the extraordinary jurisdiction of the Court cannot be invoked in the absence of a direct and substantial injury.

¶53

Detailed headnote1 paragraphs

Writ Petition (WPS) No. 4923 of 2023, High Court of Chhattisgarh at Bilaspur, decided 06/04/2026 by Hon'ble Mr. Justice Amitendra Kishore Prasad. The petitioner, Smt. Rajkumari Baiga, elected Member and Chairman of the General Administration Committee of Janpad Panchayat Bharatpur, sought (i) a writ of quo warranto against respondent Nos. 7-14 holding posts of Anganwadi Worker, and (ii) quashing of their appointment orders dated 19/05/2023, alleging disregard of the Guidelines dated 02/04/2008 (expiry of the selection period despite an objection raised in the committee meeting of 17/04/2023, non-compliance with local residence criteria, absence of BPL/reservation weightage, and alleged collection of illegal gratification). HELD: the petitioner does not possess the requisite locus standi - only a person aggrieved, having a direct and substantial interest, is entitled to invoke the writ jurisdiction; no enforceable or individual legal right of the petitioner was demonstrated to have been infringed. The writ petition was dismissed solely on the ground of want of locus standi; the legality of the impugned appointments was not adjudicated.

¶1

¶2

RAGHVENDRAJAT Digitallysigned byRAGHVENDRA JAT

¶3

2026:CGHC:15649

¶4

NAFR

¶5

HIGH COURT OF CHHATTISGARH AT BILASPUR

¶6

WPS No. 4923 of 2023

¶7

1 - Smt. Rajkumari Baiga W/o Shri Rajesh Prasad Baiga Aged About 30 Years At Present Member Of Janpad Panchayat Bharatpur And Holding The Post Chairmen General Administration Committee Of Janpad Panchayat Bharatpur R/o Village Seri Gram Panchayt Seri, Tehsil Bharatpur, District Manendragarh Chirmiri Bharatpur (Further Called Mcb) Chhattisgarh.

¶8

... Petitioner(s)

¶9

versus

¶10

1 - State Of Chhattisgarh Through The Secretary, Department Of Women And Child Welfare Indravati Bhawan, Mantralaya, Atal Nagar Raipur District Raipur Chahttisgarh.

¶11

2 - The Collector Koria District Koria Chhattisgarh.

¶12

3 - The Collector Mcb District Manendragarh Chirmiri Bharatpur Chhattisgarh.

¶13

¶14

4 - The Project And Program Officer Integrated Women And Child Development Mcb District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶15

5 - The Chief Executive Officer Jila Panchayat Manendragarh Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶16

6 - The Project Officer Integrated Women And Child Development Project Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶17

7 - Smt. Anjali Singh W/o Shri Akhand Pratap Singh Present Working As Anganwadi Worker At Anganwadi Centre Barkadol Janapad Panchayat Bharatpur R/o Village Larkoda Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶18

8 - Smt. Premkala D/o Shri Brijlal W/o Suraj Kumar Bansor Aged About

¶19

23 Years Present Working As Anganwadi Worker At Anganwadi Centre Kannouj Janapad Panchayat Bharatpur R/o Village Bharatpur Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶20

9 - Smt. Chandrakali Ahirwar D/o Shri Ramesh Prasad Ahirwar Present Working As Anganwadi Worker At Anganwadi Centre Bela Janapad Panchayat Bharatpur R/o Village Chirola Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶21

10 - Smt. Asha Ahirwar D/o Shri Satanram Ahirwar Present Working As Anganwadi Worker At Anganwadi Centre Karri Janapad Panchayat Bharatpur R/o Village Marisarai Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶22

¶23

11 - Smt. Sangeeta Mishra W/o Shri Awdhesh Mishra Present Working As Anganwadi Worker At Anganwadi Centre Baghwar Janapad Panchayat Bharatpur R/o Village Bhagwanpur Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶24

12 - Smt. Shanti Singh W/o Shri Vijaybahadur Singh Present Working As Anganwadi Worker At Anganwadi Centre Ghughri Janapad Panchayat Bharatpur R/o Village Harchoka Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶25

13 - Sukhiya W/o Shri Chunnelal Present Working As Anganwadi Worker At Anganwadi Centre Marisarai Janapad Panchayat Bharatpur R/o Village Marisari Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶26

14 - Smt. Sangeeta Baiga W/o Baijnath Baiga Present Working As Anganwadi Worker At Anganwadi Centre Rend Janapad Panchayat Bharatpur R/o Village Bagwanpur Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.

¶27

... Respondent(s)

¶28

For Petitioner(s)	: Mr. Shivam Mishra, Advocate.
For Respondent(s)/State	: Ms. Vartika Shrivastava, Panel Lawyer.
For Respondent No. 7	: Mr. Shivam Agrawal, Advocate.

¶29

Hon’ble Mr. Justice Amitendra Kishore Prasad

¶30

Order on Board

¶31

06/04/2026

¶32

By way of this petition, the petitioner has prayed for following

¶33

reliefs:-

¶34

¶35

“10.1. That, the Hon ble Court may kindly be pleased to call for the records pertaining to appointment of the respondent No. 7 to 14 from the respondent no 4 & 5 for kind perusal of this Hon’ble Court.

¶36

10.2 That, the Hon'ble Court may kindly be pleased to issue writ in nature of Que-warrento to the respondent No. 7 to 14 how they are holding the post of Anganwadi worker in their respective Centre.

¶37

10.3 That, the Hon' ble Court may kindly be pleased to issue set-aside the order dated 19/05/2023 of the appointment of the respondent No 7 to 14 on consequence of illegal appointment made by the respondent No. 4 & 5.

¶38

10.4 That, the Hon'ble Court may kindly be pleased to issue direction to investigation in this matter by any competent authority to corruption was commits in this case.

¶39

10.5. Any other relief which the Hon' ble Court may deem fit, in the interest of justice.”

¶40

Brief facts of the case, is that, the petitioner is a duly elected Member of Janpad Panchayat Bharatpur and is presently holding the post of Chairman, General Administration Committee, Janpad Panchayat Bharatpur, and in the present appointment proceedings the General Administration Committee has a participatory role as the matter is required to be placed before it

¶41

¶42

for approval. Respondent Nos. 4 and 5 are the appointing authorities for the appointment of respondent Nos. 7 to 14, however such appointments are required to be made strictly in accordance with the Guidelines of 2008 governing the appointment of Anganwadi Worker/Sahayika/Mini Worker, which prescribe the procedure for concluding the appointment process. The General Administration Committee, Janpad Panchayat Bharatpur, considered the issue and resolved in favour of the petitioner to challenge the impugned appointments dated 19/05/2023 before the Hon’ble High Court. Respondent No. 5 issued an advertisement dated 22/08/2022 for appointment to 45 Anganwadi Centres under Janpad Panchayat Bharatpur, fixing the last date for submission of applications as 05/09/2022, which was later extended to 12/09/2022, pursuant to which 36 posts were filled within the prescribed time while 9 posts remained vacant, and copies of the advertisements dated 22/08/2022 and 09/05/2022. Thereafter the remaining 9 posts were placed before the General Administration Committee for approval, and a meeting was convened on 17/04/2023 wherein a committee member, Shri Durga Shankar Misra, raised an objection regarding the expiry of the selection period as per the applicable guidelines and suggested issuance of a fresh advertisement and initiation of fresh proceedings. Despite the aforesaid objection and proposal, respondent No. 4 arbitrarily overlooked the same and, behind the back of the petitioner, endorsed remarks and proceeded to issue

¶43

¶44

the appointment orders dated 19/05/2023 in favour of respondent Nos. 7 to 14. The applicable Guidelines dated 02/04/2008, as framed and applicable, have been disregarded by the respondents while making the impugned appointments. Hence, this petition.

¶45

Learned counsel for the petitioner submits that being the Chairman of the General Administrative Committee of the Janpad Panchayat, is duly empowered and has the locus to challenge the manifest illegality and arbitrariness committed by respondent Nos. 4 and 5 in the matter of appointment of Anganwadi Workers, which has been carried out in clear violation of the prescribed guidelines and in a manner actuated by extraneous considerations. It is further submitted that respondent Nos. 7 to 14 have been appointed illegally despite the availability of more eligible candidates, as the appointments suffer from grave irregularities, including non-compliance with the mandatory condition of local residence, inasmuch as several appointees do not belong to the concerned villages for which appointments were made. Additionally, due weightage has not been accorded in accordance with the criteria such as BPL status and reservation categories, and in certain cases the selection process itself has not been concluded within the stipulated time prescribed under the governing guidelines, thereby vitiating the entire process. It is also submitted that respondent Nos. 4 and 5, motivated by pecuniary and ulterior considerations, have deliberately

¶46

¶47

overlooked the binding norms and have acted in a manner contrary to the principles of fairness, transparency, and legality, and there are serious allegations that substantial illegal gratification has been collected from respondent Nos. 7 to 14 for securing such appointments, which warrants a thorough and impartial inquiry. In these circumstances, the impugned appointments dated 19/05/2023 are liable to be set aside as being illegal, arbitrary, and unsustainable in the eyes of law, and this Hon’ble Court may graciously be pleased to quash the same, with liberty to raise any additional grounds at the time of hearing.

¶48

Learned counsel for respondent No. 7 as well as the State jointly submits that the selection and appointment of respondent Nos. 7 to 14 to the post of Anganwadi Worker have been carried out strictly in accordance with the procedure prescribed under the applicable guidelines dated 02.04.2008. It is further submitted that the entire selection process was undertaken by a duly constituted Selection Committee, adhering to all prescribed legal norms and procedural safeguards, and therefore no illegality, arbitrariness or irregularity can be attributed to the respondent authorities in making such appointments. It is also contended that the petitioner, being a Member of the Janpad Panchayat and serving as the President of the General Administrative Committee, was not only present during the relevant proceedings but was also fully aware of and participated in the selection process, and thus is estopped from challenging the same at this stage. The learned counsel

¶49

¶50

further submits that, in connection with the present matter, respondent No. 6 had duly submitted a report before respondent No. 4 on 14.06.2024, which has been brought on record. In light of the aforesaid facts and circumstances, it is emphatically urged that the grounds raised by the petitioner are misconceived, untenable in law, and devoid of any merit, and as such, the present writ petition deserves to be dismissed.

¶51

I have heard learned counsel for the parties and perused the material available on record.

¶52

Considering the facts and circumstances of the present case, this Court is of the considered opinion that the petitioner does not possess the requisite locus standi to challenge the appointments of respondents No. 7 to 14 on the alleged ground of illegality, nor to seek the quashment of the order dated 19.05.2023. It is a settled principle of law that only a person aggrieved, having a direct and substantial interest in the matter, is entitled to invoke the writ jurisdiction of this Court. In the absence of such standing, the present challenge cannot be sustained in the eyes of law.

¶53

Accordingly, in view of the foregoing discussion and upon a careful consideration of the facts and circumstances of the case, the present writ petition is hereby dismissed solely on the ground that the petitioner lacks the requisite locus standi to assail the appointments of respondents No. 7 to 14, inasmuch as no enforceable or individual legal right of the petitioner is demonstrated to have been infringed or adversely affected. It is

¶54

¶55

well settled that the extraordinary jurisdiction of this Court cannot be invoked in the absence of a direct and substantial injury, and in the present case, the petitioner has failed to establish any such

¶56

prejudice warranting judicial interference.

¶57

Sd/-

¶58

(Amitendra Kishore Prasad) Judge

¶59

Raghu Jat

Parties & counsel

AI extract

petitioner
Smt. Rajkumari Baiga W/o Shri Rajesh Prasad Baiga Aged About 30 Years At Present Member Of Janpad Panchayat Bharatpur And Holding The Post Chairmen General Administration Committee Of Janpad Panchayat Bharatpur R/o Village Seri Gram Panchayt Seri, Tehsil Bharatpur, District Manendragarh Chirmiri Bharatpur (Further Called Mcb) Chhattisgarh.¶7
Mr. Shivam Mishra, Advocate
respondent
State Of Chhattisgarh Through The Secretary, Department Of Women And Child Welfare Indravati Bhawan, Mantralaya, Atal Nagar Raipur District Raipur Chahttisgarh.¶10
Ms. Vartika Shrivastava, Panel Lawyer
respondent
The Collector Koria District Koria Chhattisgarh.¶11
respondent
The Collector Mcb District Manendragarh Chirmiri Bharatpur Chhattisgarh.¶12
respondent
The Project And Program Officer Integrated Women And Child Development Mcb District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶14
respondent
The Chief Executive Officer Jila Panchayat Manendragarh Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶15
respondent
The Project Officer Integrated Women And Child Development Project Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶16
respondent
Smt. Anjali Singh W/o Shri Akhand Pratap Singh Present Working As Anganwadi Worker At Anganwadi Centre Barkadol Janapad Panchayat Bharatpur R/o Village Larkoda Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶17
Mr. Shivam Agrawal, Advocate
respondent
Smt. Premkala D/o Shri Brijlal W/o Suraj Kumar Bansor Aged About 23 Years Present Working As Anganwadi Worker At Anganwadi Centre Kannouj Janapad Panchayat Bharatpur R/o Village Bharatpur Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶18
respondent
Smt. Chandrakali Ahirwar D/o Shri Ramesh Prasad Ahirwar Present Working As Anganwadi Worker At Anganwadi Centre Bela Janapad Panchayat Bharatpur R/o Village Chirola Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶20
respondent
Smt. Asha Ahirwar D/o Shri Satanram Ahirwar Present Working As Anganwadi Worker At Anganwadi Centre Karri Janapad Panchayat Bharatpur R/o Village Marisarai Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶21
respondent
Smt. Sangeeta Mishra W/o Shri Awdhesh Mishra Present Working As Anganwadi Worker At Anganwadi Centre Baghwar Janapad Panchayat Bharatpur R/o Village Bhagwanpur Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶23
respondent
Smt. Shanti Singh W/o Shri Vijaybahadur Singh Present Working As Anganwadi Worker At Anganwadi Centre Ghughri Janapad Panchayat Bharatpur R/o Village Harchoka Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶24
respondent
Sukhiya W/o Shri Chunnelal Present Working As Anganwadi Worker At Anganwadi Centre Marisarai Janapad Panchayat Bharatpur R/o Village Marisari Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶25
respondent
Smt. Sangeeta Baiga W/o Baijnath Baiga Present Working As Anganwadi Worker At Anganwadi Centre Rend Janapad Panchayat Bharatpur R/o Village Bagwanpur Janapad Panchayat Bharatpur District Manenadragarh Chirmiri Bharatpur Chhattisgarh.¶26

Coram

AI extract

Amitendra Kishore Prasadauthor¶29

Smt. Rajkumari Baiga v. State of Chhattisgarh

Case brief

What is this about?

What did the court decide?

Smt. Rajkumari Baiga v. State of Chhattisgarh

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Rampukar Singh Vs State of Chhattisgarh

Shiv Tandon Vs State of Chhattisgarh

Kaushik Behra Vs the State of Chhattisgarh

Amarchand Pahare, Vs Chhattisgarh State Information Commission

Laxmikant Sahu Vs State of Chhattisgarh

Gangadhar Patel Vs State of Chhattisgarh