Madhya Pradesh High Court
Ms. Manisha Chharel vs The Security Printing And Minting ... on 12 January, 2026
NEUTRAL CITATION NO. 2026:MPHC-IND:908
1 W.P. No.45543/2025
IN THE HIGH COURT OF MADHYA PRADESH
AT INDORE
BEFORE
HON'BLE SHRI JUSTICE JAI KUMAR PILLAI
WRIT PETITION No.45543 of 2025
MS. MANISHA CHHAREL
Versus
THE SECURITY PRINTING AND MINTING CORPORATION
Appearance:
Shri L.C. Patne - Advocate for the petitioner.
Shri Vivek Patwa - Advocate for respondents.
_______________________________________________________
Reserved on : 09/12/2025
Post on : 12/01/2026
Signature Not Verified
Signed by: JAGADISHAN
AIYER
Signing time: 12-01-2026
17:23:45
NEUTRAL CITATION NO. 2026:MPHC-IND:908
2 W.P. No.45543/2025
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ORDER
The petitioner has approached this Court by filing this Writ Petition under Article 226 of the Constitution of India seeking following reliefs:-
"(a) call for the relevant records of the case;
(b) to quash the impugned order dated 30.9.2025 (Annexure P/12) issued by respondent No.2, by a writ of certiorari or any other appropriate writ, direction or order.
(c) to command the respondents to resintate the petitioner on the post of Trainee (Junior Office Assistant) with full back wages along with all consequential and monetary benefits along with interest @ 12% p.a by a writ of mandamus or any other appropriate writ, direction or order;
(d) to allow this petition with costs;
(e) to pass such other order(s} as this Hon'ble Court may deem fit in the fact and circumstance of the case to grant relief to the petitioner."
2. It is the case of the petitioner that she belongs to the Bhilala caste, which is notified as a Scheduled Tribe. The petitioner possesses requisite educational qualifications, including a Bachelor of Business Administration Degree obtained in 2020, a Master of Commerce Degree obtained in 2022, a Diploma in Computer Application obtained in 2014, Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 3 W.P. No.45543/2025 successful completion of a Hindi-English Typing Examination and a National Trade Certificate in Computer Operator and Programming Assistant. It is further stated that the petitioner‟s father, Late Shri Kailash Chandra Chharel, died in harness on 29th March 2021 while serving as Senior Checker in the Bank Notes petitioner‟s mother, Smt. Urmila Chharel, also expired, leaving the petitioner without parental support.
3. It is further the case of the petitioner that being a dependent family members under the applicable Compassionate Appointment Scheme, 2012, she duly applied for Compassionate Appointment and submitted all requisite documents, including affidavits disclosing her dependency on the deceased employee and the independent financial status and employment of her elder brother, who was not dependent upon the deceased employee. Upon due verification of her credentials, the competent authority issued an appointment order dated 29 January 2025 appointing her on compassionate grounds to the post of Trainee (Junior Office Assistant) in the prescribed pay scale. Pursuant thereto, the petitioner joined her duties and continuously discharged the same sincerely and diligently, and was also allotted Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 4 W.P. No.45543/2025 residential accommodation in consequence of her appointment.
4. It is lastly contended that despite the above, a show cause notice dated 17 May 2025 was issued to the petitioner alleging suppression of the fact regarding the employment of her elder brother in the Police Department, to which the petitioner submitted a detailed reply seeking dropping of the proceedings. However, by an order dated 30 September 2025, the respondent authority cancelled the petitioner‟s compassionate appointment and dismissed her from service by casting a stigma, without conducting any departmental or fact-finding inquiry, and without examining the undisputed position that the petitioner‟s elder brother had been in government service since 2013, was residing separately with his own family, and was financially independent and not dependent upon the deceased employee. Aggrieved by the said arbitrary and illegal action, the petitioner has approached this Hon‟ble Court seeking appropriate relief.
5. The counsel for the petitioner submits that the petitioner had duly informed the concerned department regarding the employment of her elder brother, Shri Rajendra Chharel, in the Police Department of the Government of Madhya Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 5 W.P. No.45543/2025 Pradesh. It is contended that the elder brother had also sworn an affidavit affirming his employment, his separate residence, and the fact that he was not dependent upon the earnings of the deceased father, which affidavit was submitted along with the petitioner‟s application for compassionate appointment. Therefore, it is asserted that at no stage was there any suppression of facts by the petitioner. It is further submitted that the elder brother, having been in government service since 2013, residing separately, and maintaining his own family, does not fall within the definition of a "dependent" under Clause 5.4 of the SPMCIL Compassionate Appointment Scheme, 2012.
6. It is further submitted by counsel for the petitioner that once the elder brother is not to be treated as a dependent of the deceased employee, the question of mentioning his employment in the application for compassionate appointment does not arise in the facts and circumstances of the case. The counsel contends that no departmental inquiry, much less any fact-finding inquiry, was conducted by the respondents to ascertain the separate residence, independent financial status, or non-dependence of the elder brother, despite the requirement to do so as laid down in the binding Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 6 W.P. No.45543/2025 judgments of the Division Bench of this Court in State of M.P. v. Mahmood Hussain Mansuri and Karuna Bhatt v. State of M.P. and Others passed in W.A. No.729/2013 decided on 25/06/2014.
7. The counsel for the petitioner further submits that the petitioner is duly qualified for the post of Junior Office Assistant and had been discharging her duties sincerely, diligently and without any blemish, yet her services were discontinued purportedly under the Compassionate Appointment Policy of 2012. It is urged that the petitioner is suffering severe mental and financial hardship on account of her unemployment and has been forced into a life of penury, which is violative of her right to life and dignity guaranteed under Article 21 of the Constitution of India. The petitioner, therefore, seeks appropriate reliefs including judicial review of the impugned action, reinstatement with consequential benefits, and such other orders as this Hon‟ble Court may deem fit in the interests of justice.
8. The counsel for the respondents vehemently opposed all the allegations raised by the petitioner by submitting that Bank Note Press, Dewas is an Industrial Unit under the Security Printing and Minting Corporation of India Limited Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 7 W.P. No.45543/2025 (SPMCIL), a Miniratna Category-I Central Public Sector Enterprise, wholly owned by the Government of India under the Ministry of Finance, Department of Economic Affairs, and engaged in printing and supplying bank notes to the Reserve Bank of India. It is stated that pursuant to the Cabinet decision dated 02.09.2005, the Government of India set up SPMCIL by merging all nine units under the Currency and Coinage Division of the Department of Economic Affairs into the newly constituted public sector enterprise. The respondents emphasized that the organization is a highly security - sensitive establishment, covered under the Official Secrets Act and declared a prohibited area by the State Government of Madhya Pradesh, where secrecy, integrity and reliability of personnel are of paramount importance.
9. It is submitted by counsel for the respondents that the petitioner challenges the termination order passed on the ground of suppression of material facts at the time of obtaining Compassionate Appointment. The father of the petitioner, who was working as Senior Checker at Bank Note Press, Dewas, died on 29.03.2021, whereafter the petitioner applied for Compassionate Appointment along with an affidavit dated 12.06.2021. In the application, Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 8 W.P. No.45543/2025 the petitioner answered "नह "ीं to the query „क्या पररवार का कोई आश्रित सदस्यp शासक य / अर्द्ध शासक य / स्वााायत्तtशास/ स्टॉwक एक्सयचेन्जUमें सूच बर्द् सावध जश्रनक उपक्रम में लाभ के पद पर श्रनयोश्रजत है (यश्रद हॉं तो श्रवभाग का उल्लेरख करें )‟ and further declared that no dependent family member was employed in any State, Central, PSU or similar organization. According to the respondents, these declarations were false, as the petitioner‟s brother was employed in the Madhya Pradesh Police and her sister was employed under the Samagra Samajik Suraksha Mission of the Government of Madhya Pradesh, and such material facts were deliberately suppressed despite self-attestation.
10. The counsel for the respondents further submitted that under the SPMCIL Compassionate Appointment Scheme, 2012, the petitioner‟s case was scrutinized and processed on the basis of the declarations furnished by her and the recommendation and acceptance of her appointment were founded solely on those disclosures. The scheme is stated to be intended to mitigate immediate financial hardship of the family of a deceased employee and expressly excludes cases where any Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 9 W.P. No.45543/2025 dependent of the deceased employee is gainfully employed in Government, semi-government, autonomous bodies, PSUs or stock-exchange-listed organizations, confining the definition of "dependent" to spouse and children not so employed. It is asserted that the object of the scheme is to assess the financial condition of the family as a whole and not the individual eligibility of one member, and that applications have consistently been rejected where siblings were found to be gainfully employed.
11. It is further submitted by counsel for the respondents that the petitioner was issued an offer of appointment as a Trainee containing a clear stipulation that in the event of any false declaration or willful suppression of material information, she would be liable to removal from service at any time, which condition was duly self-attested by her. Upon subsequent scrutiny and verification, suppression regarding the employment status of the petitioner‟s brother and sister was detected, whereafter a show-cause notice was issued, the reply was considered, and an opportunity of hearing was granted. After due deliberation, including re-verification by a fact-finding committee, and keeping in view the security- sensitive nature of the organization and the oath of secrecy Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 10 W.P. No.45543/2025 taken by the petitioner, the competent authority passed the termination order. The respondents maintain that the prescribed procedure was strictly followed, the petitioner was ineligible for compassionate appointment from the outset, and the impugned order has been lawfully passed in accordance with the applicable scheme and rules.
12. Heard counsel for both the parties at length.
13. This Court is of the view that the undisputed facts clearly establish that the petitioner is fully eligible for Compassionate Appointment under the applicable Scheme. 2012. The petitioner possesses the requisite educational qualifications for the post of Trainee (Junior Office Assistant) and was appointed only after due verification by the Competent Authority. The death of the petitioner‟s father in harness on 29.03.2021, followed by the demise of her mother within days, left the petitioner without parental support and squarely brought her within the zone of consideration as a dependent family member. The petitioner joined service pursuant to the appointment order dated 29.01.2025 and discharged her duties sincerely, without any adverse remark, which fortifies her bona fides and suitability for the post.
Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45NEUTRAL CITATION NO. 2026:MPHC-IND:908 11 W.P. No.45543/2025
14. This Court has also considered that the allegation of suppression of facts regarding the employment of the petitioner‟s elder brother is wholly misconceived and unsupported by the record. The material placed before the Court demonstrates that the elder brother had been in government service since 2013, was residing separately with his own family, and was financially independent. An affidavit to this effect was duly submitted along with the petitioner‟s application, and therefore, it cannot be said that there was any concealment or misrepresentation on the part of the petitioner. In view of Clause 5.4 of the SPMCIL Compassionate Appointment Scheme, 2012, such an independently employed and separately residing brother does not fall within the definition of a "dependent," rendering the basis of the impugned action legally untenable. It was contended that the sister of the petitioner is employed under the Samagra Samajik Suraksha Mission of the Government of Madhya Pradesh, however, the said contention remains wholly unsubstantiated, as no documentary material has been placed on record in support thereof. Even otherwise, the impugned order dated 30.09.2025 does not advert to or rely upon this objection. Consequently, this Court finds no Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 12 W.P. No.45543/2025 justification to dwell upon an objection which does not form part of the reasons recorded in the impugned order. In the absence of any material on record to establish that the sister of the petitioner is a dependent, the said contention deserves to be rejected.
15. This Court has further observed that the impugned order dated 30.09.2025 cancelling the petitioner‟s appointment and dismissing her from service is vitiated by gross violation of the principles of natural justice. The order casts a clear stigma upon the petitioner, yet no departmental inquiry or even a fact-finding inquiry was conducted to verify the alleged suppression or to examine the undisputed aspects of separate residence and non-dependence of the elder brother. Such an action is contrary to settled law, as held in catena of judgment pronounced by Hon‟ble Apex court, which mandate due inquiry before taking any punitive or stigmatic action, even in matters relating to Compassionate Appointment.
16. This Court further considers that the arbitrary termination of the petitioner, after she had already joined service and settled into employment, has resulted in grave financial and mental hardship, defeating the very object of Compassionate Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45 NEUTRAL CITATION NO. 2026:MPHC-IND:908 13 W.P. No.45543/2025 Appointment. The impugned order cannot be sustained in law and deserves to be quashed. Consequently, the writ petition is allowed and the order dated 30.09.2025 is set aside and the respondents are directed to reinstate the petitioner forthwith on the post of Trainee (Junior Office Assistant) with continuity of service with all consequential benefits from the date of termination, till the date of re-instatement.
17. No order as to costs.
18. Pending applications, if any, shall be disposed of accordingly.
(Jai Kumar Pillai) Judge Aiyer*BL Signature Not Verified Signed by: JAGADISHAN AIYER Signing time: 12-01-2026 17:23:45