The Karnataka High Court has declined to reinterpret the definition of “family” under the Karnataka Civil Services (Appointment on Compassionate Grounds) Rules, 1996, to include a widowed daughter-in-law for compassionate appointment purposes. The court held that expanding the statutory definition of “family” through judicial interpretation would amount to rewriting the law, which is beyond the court’s jurisdiction.
The decision was rendered by a division bench comprising Justice Krishna S. Dixit and Justice Vijaykumar A. Patil in the case of Smt. Priyanka Halamani vs. State of Karnataka & Others (WP No. 105264 of 2024).
Background of the Case
The petitioner, Smt. Priyanka Halamani, a 27-year-old widow, sought to challenge the Karnataka State Administrative Tribunal’s (KSAT) order dated January 4, 2024, which denied her application for compassionate appointment following the death of her husband, Praveen Halamani. Priyanka argued that the rules under the Karnataka Civil Services (Appointment on Compassionate Grounds) Rules, 1996, were arbitrary as they did not include a widowed daughter-in-law in the definition of “family.” She requested the court to read down Rule 2(b)(ii) to include her within the ambit of “family” for compassionate appointment.
Represented by Advocate Shivraj S. Balloli, Priyanka contended that excluding a widowed daughter-in-law from the definition of “family” was discriminatory and violated the principles of fairness and justice. She cited a decision by the Allahabad High Court in the case of U.P. Power Corporation Ltd. vs. Urmila Devi to support her argument.
The respondents, represented by Government Advocate G.K. Hiregoudar, opposed the petition, arguing that the definition of “family” was a policy decision made by the rule-making authority. He argued that the judiciary should not interfere with or expand this definition, citing the doctrine of separation of powers as a core principle of the Constitution.
Legal Issues Involved
The central legal issue was whether the judiciary could reinterpret or expand the statutory definition of “family” under Rule 2(b)(ii) of the Karnataka Civil Services (Appointment on Compassionate Grounds) Rules, 1996, to include a widowed daughter-in-law. The petitioner urged the court to apply the doctrine of “reading down” to include her in the definition.
Court’s Observations and Decision
Justice Krishna S. Dixit, delivering the judgment, declined to expand the definition of “family” to include a widowed daughter-in-law, stating:
“Courts cannot add or delete from a statutory definition of family. An argument to the contrary would amount to rewriting the rule, which is impermissible.”
The court referred to the Supreme Court’s observation in Minerva Mills vs. Union of India and other landmark judgments to reinforce the doctrine of separation of powers. The bench emphasized:
“The doctrine of reading down may be invoked if a statute is ambiguous or admits more than one interpretation. However, when the legislative intent is clear, the judiciary must refrain from expanding or altering the statutory framework.”
The court further elaborated that the judiciary’s role is limited to interpreting the law and ensuring its compliance with constitutional provisions, not altering its scope. Justice Dixit observed:
“The courts should confine themselves to the conventional limits of the judicial process and not intrude into the domain of the legislature, which is tasked with framing public policy.”
The court also distinguished the present case from the Allahabad High Court’s decision in U.P. Power Corporation Ltd. vs. Urmila Devi, noting that the latter did not consider the doctrine of separation of powers as a basic feature of the Constitution.
Case Details:
– Case Number: WP No. 105264 of 2024
– Judges: Justice Krishna S. Dixit and Justice Vijaykumar A. Patil
– Petitioner: Smt. Priyanka Halamani, W/o Late Praveen Halamani, Bagalkot
– Respondents:
– 1. State of Karnataka, Rural Drinking Water and Sanitation Department
– 2. Commissioner, Rural Drinking Water and Sanitation Department
– 3. Superintending Engineer, Rural Drinking Water and Sanitation Circle, Dharwad
– Lawyers:
– For Petitioner: Advocate Shivraj S. Balloli
– For Respondents: Government Advocate G.K. Hiregoudar
– Date of Judgment: September 9, 2024
– Relevant Laws: Karnataka Civil Services (Appointment on Compassionate Grounds) Rules, 1996
