In a significant ruling, the Allahabad High Court dismissed a petition filed by the Anjuman Himayat Chaprasian Sangh, U.P., an association representing Class IV employees working in civil courts across Uttar Pradesh. The petition alleged that these employees were being compelled to perform domestic duties at the residences of judicial officers, which, according to the association, was beyond their official responsibilities.
Case Background
The case, Writ – A No. 1578 of 2025, was filed by the association through its Provincial Chairman, Brij Kishor Sharma, against the State of Uttar Pradesh, represented by the Principal Secretary, Department of Law and Legal Remembrance, and the High Court. The petitioner was represented by Advocate Anil Kumar Pandey, while the respondents were represented by the Standing Counsel for the State of U.P. and Advocate Gaurav Mehrotra for the High Court.
The petitioners argued that Class IV employees, who are governed by the Uttar Pradesh District Court Service Rules, 2013, were being forced to work at the residences of judicial officers, performing tasks unrelated to their official duties. They sought a directive prohibiting such alleged practices.
Legal Issues and Court’s Observations
The primary issue before the Court was whether an association could file a writ petition under Article 226 of the Constitution on behalf of its members. Citing the precedent set in Umesh Chand Vinod Kumar & Ors. Vs. Krishi Utpadan Mandi Samiti, Bharthana & Anr. (1983 SCC OnLine All 638), the Court examined whether the association had the legal standing to file such a petition.
Justice Alok Mathur, presiding over the case, referred to previous rulings and held that an association can file a petition for the enforcement of its members’ rights only under specific conditions:
If the members themselves are unable to approach the Court due to poverty, disability, or disadvantageous social/economic positions.
In cases involving public interest litigation where the association has a special interest in the subject matter.
If the association’s rules explicitly authorize it to initiate legal proceedings on behalf of its members.
The Court noted that none of these conditions applied in the present case, as the aggrieved employees were not incapacitated in any manner from individually approaching the Court. Moreover, the association’s bye-laws did not authorize it to take legal action on behalf of its members.
Dismissal of the Petition
The Court further questioned the petitioner’s counsel on why judicial officers should not be assisted by staff in their official work, including tasks such as carrying files to and from their residences. The petitioner failed to provide a satisfactory response. The respondents argued that Class IV employees assist judicial officers in legal work, including handling case files, which is an integral part of their service and not an instance of forced labor.
In light of these observations, Justice Mathur concluded:
“Facilities are provided to judicial officers, and it is Class IV employees who carry files and other material from the courts to the residences and vice versa. They assist the judicial officers in the dispensation of justice, and this cannot be said to be forced labor or taking any work beyond the prescribed duties.”
On these grounds, the Court held that the petition was not maintainable and dismissed it accordingly.
