Introduction:

In Paras Saklecha v. State of Madhya Pradesh & Ors., Writ Petition No. 49798 of 2025, the High Court of Madhya Pradesh dismissed a Public Interest Litigation challenging the alleged arbitrary implementation of the Mukhyamantri Ladli Behna Yojana, 2023. The Division Bench comprising Justice Vijay Kumar Shukla and Justice Alok Awasthi held that executive policy decisions are not subject to judicial interference unless shown to be unconstitutional, arbitrary, mala fide, or contrary to statutory provisions.

The petitioner had assailed the State Government’s decision to stop fresh registrations under the scheme with effect from 20 August 2023 and challenged the age criteria prescribed therein. It was contended that the closure of registrations, despite the scheme being ongoing and benefiting over 1.26 crore women, amounted to discrimination under Article 14 of the Constitution.

Rejecting these contentions, the Court reiterated the well-settled principles governing judicial review of policy decisions. It emphasized that courts do not evaluate the wisdom or desirability of welfare schemes and cannot substitute their views for that of the executive. Judicial scrutiny, the Bench clarified, is confined strictly to legality.

Background of the Scheme:

The Mukhyamantri Ladli Behna Yojana was introduced on 1 March 2023 as a flagship welfare initiative aimed at women empowerment in the State of Madhya Pradesh. The scheme sought to improve health and nutrition, promote economic independence, and strengthen women’s participation in family decision-making processes.

Under Clause 6.1 of the policy, eligible women domiciled in Madhya Pradesh were entitled to receive ₹1,000 per month directly in their bank accounts. This amount was subsequently enhanced to ₹1,250 through administrative orders.

The eligibility criteria prescribed that beneficiaries must be married women, including widows, divorced and abandoned women, between the ages of 23 and 60 years. Later, by an order dated 19 July 2023, the minimum age was reduced from 23 to 21 years.

However, on 20 August 2023, the State Government decided to stop fresh registrations under the scheme. While the benefits continued for existing beneficiaries, newly eligible women were not permitted to register.

It was this decision—along with the age criteria—that formed the core of the challenge in the PIL.

Petitioner’s Arguments:

The petitioner contended that the scheme was of a continuing nature and was designed to benefit a broad class of eligible women. Given that over 1.26 crore women were already receiving benefits, the closure of fresh registrations was arbitrary and discriminatory.

It was argued that denying similarly situated women the benefit of the scheme, solely because of an administrative cut-off date, amounted to hostile discrimination under Article 14 of the Constitution. The petitioner asserted that once the State formulated a welfare policy aimed at empowerment, it could not arbitrarily exclude a section of eligible beneficiaries without rational justification.

The petitioner further challenged the fixation of the minimum age of 21 years and maximum age of 60 years as arbitrary. It was contended that such age limits lacked a rational nexus with the object of the scheme. The objective being women empowerment and economic independence, excluding women below 21 and above 60 years was allegedly unjustified.

Additionally, it was submitted that the State had publicly promised enhancement of the scheme amount, and failure to implement such enhancement indicated arbitrariness and inconsistency in policy execution.

On these grounds, the petitioner sought directions to reopen registration and extend benefits to all eligible women during the subsistence of the scheme.

State’s Arguments:

The State of Madhya Pradesh opposed the PIL on both maintainability and merits.

On maintainability, the State contended that the scheme was a pure executive policy decision. None of the aspirants or beneficiaries had approached the Court alleging denial of rights. The petitioner himself was neither an aspirant nor a beneficiary. Therefore, it was argued that the PIL was not maintainable.

On merits, the State submitted that decisions regarding commencement, continuation, and closure of registrations under a welfare scheme fall squarely within the executive domain. Courts cannot direct the State to modify policy decisions unless they violate constitutional or statutory mandates.

The State further contended that prescribing age limits is an essential component of any targeted welfare scheme. The State must balance fiscal resources, administrative feasibility, and policy priorities. The fixation of age criteria was thus a rational policy choice aligned with the scheme’s objectives.

It was emphasized that judicial review does not extend to evaluating the wisdom, financial implications, or desirability of policy decisions.

Judicial Review of Policy Decisions:

The Division Bench reiterated settled jurisprudence governing judicial review of executive policy. Referring to landmark decisions such as Balco Employees Union v. Union of India, Narmada Bachao Andolan v. Union of India, State of M.P. v. Nandlal Jaiswal, and Villinaur Iyarkkai Padukappu Maiyam v. Union of India, the Court observed that courts refrain from interfering with policy decisions merely because another view is possible.

The Bench emphasized that judicial review is confined to examining whether the policy is unconstitutional, beyond statutory powers, arbitrary, mala fide, or contrary to law. Courts do not sit in appeal over economic or welfare policies.

Relying further on Delhi Development Authority v. Joint Action Committee, Allottee SFS Flats, the Court noted that interference is permissible only if a policy is unconstitutional, dehors statutory provisions, or beyond delegated authority.

Court’s Analysis and Findings:

On Closure of Registrations:

The Court held that fixing a date for commencement and closure of registrations under a welfare scheme is an administrative decision falling within the exclusive domain of the State Government. The petitioner failed to demonstrate how the decision was arbitrary or discriminatory.

The Bench observed that every welfare scheme must operate within financial and administrative constraints. Setting a cut-off date is a common and permissible method to regulate implementation. The mere fact that some eligible persons may be excluded due to a cut-off date does not render the policy unconstitutional.

On Age Criteria:

The Court held that prescribing minimum and maximum age limits is a legitimate policy decision. Considering the nature of the scheme—aimed at empowering married women within a defined age bracket—the age criteria did not suffer from arbitrariness.

The State is entitled to identify a target group based on rational considerations. Courts cannot expand the beneficiary class by substituting their judgment for that of the executive.

On Enhancement of Scheme Amount:

As regards the grievance about non-implementation of the promised enhancement, the Court declined to entertain the issue. The petitioner was neither a beneficiary nor an aspirant. Such grievances, if any, must be raised by affected individuals and not in a generalized PIL.

Conclusion of the Court:

Concluding that the case did not fall within the limited grounds warranting judicial interference, the Court dismissed the PIL without costs. The Bench reiterated that policy decisions of the State are not amenable to judicial review unless they violate constitutional or statutory provisions.

The judgment reinforces the doctrine of separation of powers, emphasizing judicial restraint in matters of economic and welfare policy.

Legal Significance:

The ruling underscores:

Judicial Restraint: Courts do not evaluate the wisdom of welfare schemes.

Limited Scope of Review: Only illegality, arbitrariness, mala fides, or constitutional violations invite interference.

Legitimacy of Cut-Off Dates: Administrative closure of registrations is permissible.

Policy Domain of Executive: Age criteria and beneficiary classification fall within executive discretion.

PIL Maintainability: General grievances cannot be agitated by non-affected persons.

This judgment affirms that courts respect executive autonomy in policy formulation while safeguarding constitutional boundaries.