Unauthorized Absence: Madhya Pradesh High Court Dismisses Appeal of Anganwadi Worker Against Termination

The Madhya Pradesh High Court has dismissed a writ appeal filed by an Anganwadi worker challenging her termination on grounds of alleged unauthorized absence, holding that the principles of natural justice were duly complied with and that the appellant failed to substantiate her claims of illness and procedural unfairness.

The Division Bench comprising Justice Vivek Rusia and Justice Pradeep Mittal was hearing a plea by Smt. Priyanka Pal, who had questioned the legality of her termination and the subsequent dismissal of her writ petition by a Single Judge. The Court ultimately found no merit in her challenge, affirming the earlier findings that adequate opportunity had been provided and that the termination was not arbitrary.

The appellant had contended that she was appointed as an Anganwadi Karyakarta in 2007 and had discharged her duties satisfactorily until she fell ill in November 2008. She argued that she had submitted leave applications along with medical certificates but due to a curfew in the district, these could not reach the authorities. Her services were terminated in January 2009 without a show cause notice, she claimed, rendering the action violative of natural justice.

However, the State countered these claims by asserting that the appellant had misrepresented facts, particularly regarding her illness. It pointed to inconsistencies in her submissions, including discrepancies between her explanation and the medical certificate produced. The authorities maintained that a show cause notice had indeed been issued and properly served through affixture, but the appellant failed to respond.

The Court, agreeing with the State’s position, observed that the record clearly established compliance with procedural requirements. It noted that “the appellant/writ petitioner was terminated from service on account of unauthorized absence after due issuance of a show cause notice dated 16/01/2009, which was duly served by affixture and remained unresponded to.” The Bench therefore rejected the argument that there had been any violation of natural justice.

Addressing the appellant’s reliance on medical grounds, the Court found her explanation unconvincing. It held that her plea of illness and inability to communicate due to curfew was not supported by reliable or consistent material. The judges remarked that “the medical certificate produced does not inspire confidence and is rightly disbelieved,” reinforcing the conclusion that her absence remained unjustified.

The appellant had also relied on a previous Division Bench ruling in Parvati Pawar v. State of Madhya Pradesh to argue that termination without proper adherence to natural justice is unsustainable. However, the Court distinguished that judgment on facts, noting that in the present case, the appellant failed to demonstrate any compelling circumstance such as serious illness supported by cogent evidence.

Importantly, the Bench endorsed the findings of the Single Judge, who had earlier concluded that sufficient opportunity had been afforded to the appellant and that the notice had been properly served. The Court emphasized that mere allegations of procedural lapses cannot override documentary evidence showing compliance with due process.

Dismissing the appeal, the Court concluded that the case was “devoid of substance and merit,” thereby bringing an end to the appellant’s prolonged legal challenge spanning multiple rounds of litigation.

Case Title: Smt. Priyanka Pal v. The State of Madhya Pradesh and Others

Date of Order: April 10, 2026

Bench: Justice Vivek Rusia and Justice Pradeep Mittal