HP High Court Upholds Termination of Anganwari Worker for 'Gross Insubordination'

Shimla: The Himachal Pradesh High Court has upheld the termination of an Anganwari worker, ruling that her persistent and deliberate refusal to comply with official directives to relocate an Anganwari centre amounted to "gross insubordination" that cannot be tolerated in public service.

In a judgment delivered on November 13, 2025, Justice Jyotsna Rewal Dua dismissed the writ petition filed by Lalita Devi, stating that the punishment of termination was not perverse or disproportionate given her repeated acts of defiance.

Background of the Dispute

The case originated from a complaint filed on March 24, 2023, by the Pradhan of Gram Panchayat Bhambla and several villagers. They objected to the Anganwari Centre, Sadhwani-I, being operated from the petitioner Lalita Devi's private residence, which they described as an isolated location outside the main village.

Acting on the complaint, the Child Development Project Officer (CDPO) on April 13, 2023, directed Ms. Devi to shift the centre to the centrally located Mahila Mandal Bhawan (community hall). However, Ms. Devi defied this order and instead moved the centre to the house of her brother-in-law.

Despite repeated directives on April 20, May 15, May 20, July 19, and July 26, 2023, Ms. Devi refused to comply. She defended her actions by claiming she had entered into a rent agreement with her relative. The authorities reiterated that an Anganwari Centre could not be run from the house of a worker or their relations.

A History of Defiance

The court noted that the case file was "replete with repeated directions/office letters, notices issued to the petitioner." The matter even reached the High Court in a previous petition (CWP No.5293/2023), which resulted in a directive on August 10, 2023, to resolve the issue, leading to a final order on October 21, 2023, to shift the centre.

When Ms. Devi continued to disobey, the department initiated termination proceedings under Clause 7 of the governing scheme. Three separate show-cause notices were issued to her on December 14, 2023, December 29, 2023, and January 12, 2024. Her persistent refusal led to her termination on June 27, 2024. It was only after her removal from service that the Anganwari Centre was successfully shifted to the Mahila Mandal Bhawan.

Petitioner's and Respondent's Arguments

The petitioner’s counsel argued that the punishment of termination was "too harsh" in light of her long service.

Conversely, the state's counsel defended the decision, highlighting the petitioner's consistent refusal to obey lawful orders from her superior officers, which undermined the department's functioning. The state's reply also mentioned instances of misbehavior by the petitioner's husband, leading to the filing of FIRs.

Court's Decisive Ruling on Insubordination

Justice Jyotsna Rewal Dua, in a strongly-worded judgment, found no merit in the petitioner's plea and held that her conduct was a clear case of indiscipline. The court emphasized that an employee cannot dictate the terms of their service.

> "It was not for the petitioner to decide where to run the Anganwari Centre. As an employee, all that was required of her was to abide by the directions issued to her by the higher officers and not to sit over the same and take her independent decisions contrary to the directions. It is a case of gross insubordination and indiscipline on part of the petitioner."

The court observed that the authorities had provided ample opportunities for compliance, which the petitioner ignored.

> "Faced with adamancy of the petitioner, her misconduct, extent of indiscipline, repeated misadventures and acts of insubordination, respondents acted within the confines of law and applicable Scheme in terminating her services... Insubordination cannot be taken lightly as it affects hierarchy of position and the chain of command, which in turn, affects working of employer."

Final Verdict

Concluding that the termination was neither perverse nor disproportionate, the High Court found no grounds for interference under judicial review. The writ petition was accordingly dismissed.