The State of Uttar Pradesh & Ors. vs Shanti Devi
Background
Shanti Devi, an Anganwadi worker who had crossed the prescribed upper age limit of 50 years, sought promotion/recruitment to the post of "Mukhya Sevika" and asked for an age relaxation under the U.P. Public Services (Relaxation of Age Limits for Recruitment) Rules, 1992, citing her long continuous service since 1987. The State rejected her claim, contending she was not a "government employee" since Anganwadi workers hold honorary, scheme-based positions and therefore did not fall within the Rules. A Single Judge of the Allahabad High Court had directed the State to reconsider her claim, and a Division Bench later upheld that direction, prompting the State to appeal to the Supreme Court.
Decision Breakdown
The Supreme Court noted that after the Single Judge's order, the State had in fact reconsidered Shanti Devi's representation twice and rejected it, finding that the post of Anganwadi worker is not a regular government post and so does not fall under Rule 3 of the 1992 Age Relaxation Rules. The Court held that age relaxation under these Rules is a matter of the appointing authority's discretion, not a vested right of any individual candidate, and that eligibility criteria for a competitive recruitment process (here, applied uniformly to a pool of about 70,000 eligible candidates for 975 posts) must remain uniform to avoid arbitrariness. Since no individual candidate could claim age relaxation as a matter of right and the State had validly exercised its discretion against granting it, the Court allowed the State's appeal, set aside the High Court's judgment, and dismissed Shanti Devi's original writ petition.
Lesson Learnt
Age-relaxation or similar concessions in government recruitment rules are discretionary benefits for the appointing authority to grant, not entitlements an individual can claim as of right, and courts will not second-guess a reasoned, uniformly-applied administrative decision on eligibility.