Introduction:
The Telangana High Court, in Boorla Mahesh & Ors. v. State of Telangana & Ors. [2026 LiveLaw (Tel) 101], upheld the constitutional validity of the State Government’s decision to reserve the posts of Extension Officer Grade-I and Grade-II (Anganwadi Supervisors) exclusively for women. Justice T. Madhavi Devi held that the policy is a valid exercise of the State’s power under Article 15(3) of the Constitution, which permits special provisions for women and children to achieve substantive equality.
The petitioners challenged G.O.Ms. No.14 dated June 27, 2013, by which the Government amended the recruitment rules and made only women eligible for appointment as Extension Officers in the Women Development and Child Welfare Department. Consequential recruitment notifications issued by the Telangana State Public Service Commission (TSPSC) in 2022 for 181 posts of Extension Officer Grade-I and 23 posts of Women and Child Welfare Officers and Child Development Project Officers were also challenged. The petitioners, who were male candidates, argued that the amendment unlawfully excluded them from public employment despite their ability to perform the duties attached to the posts.
The dispute primarily concerned the implementation of the Integrated Child Development Services (ICDS) Scheme, under which Extension Officers supervise Anganwadi Centres providing nutrition, health care, pre-school education and welfare services to children, adolescent girls, pregnant women and lactating mothers. The Court was therefore required to determine whether exclusive reservation of these supervisory posts for women violated the constitutional guarantees of equality or whether it was protected under Article 15(3).
Arguments of the Parties:
The petitioners contended that the impugned Government Order violated Articles 14, 19(1)(g) and 21 of the Constitution by completely excluding male candidates from consideration for public employment. They argued that the duties of an Extension Officer largely involve administrative supervision, monitoring Anganwadi Centres, maintaining official records, coordinating with health authorities, implementing welfare schemes and assisting Child Development Project Officers. According to them, none of these functions required that the post be occupied only by a woman.
The petitioners further relied upon Rule 22-A of the Telangana State and Subordinate Service Rules, 1996. Particular emphasis was placed on the proviso to Rule 22-A(1), which states that preference given to women should not result in the total exclusion of men from any category of posts. They argued that while the Rules permit preference for women where appropriate, they do not authorize complete exclusion of male candidates. The petitioners also relied upon judicial precedents including S. Renuka v. State of Andhra Pradesh and Dr. Alok Kumar Singh v. State of Uttar Pradesh, submitting that reservation should not entirely prohibit eligible male candidates from competing for public posts.
The State Government defended the policy by explaining the objectives of the ICDS Scheme. It submitted that Extension Officers supervise Anganwadi Centres where the primary beneficiaries are women and children, particularly pregnant women, lactating mothers and adolescent girls. The Government argued that the entire service delivery mechanism is centred around women beneficiaries and women Anganwadi workers. Therefore, appointing women as supervisory officers promotes better coordination, trust and effective implementation of welfare programmes.
The State further contended that Article 15(3) specifically empowers the Government to make special provisions for women. The impugned amendment represented a conscious policy decision taken after considering the nature of the beneficiaries and the sensitivity involved in implementing child welfare and maternal health programmes. TSPSC submitted that it merely implemented the recruitment policy framed by the Government and had no independent role in determining eligibility.
Court’s Judgment:
The High Court dismissed both writ petitions and upheld the validity of the Government Order reserving the posts exclusively for women.
Justice T. Madhavi Devi observed that although the duties of Extension Officers, viewed in isolation, could technically be performed by either men or women, the Court could not ignore the broader context in which these posts function. The beneficiaries of the ICDS Scheme are overwhelmingly women and children, and the primary functionaries at Anganwadi Centres are also women. The Government had therefore taken a conscious policy decision that supervisory posts should also be occupied by women in order to ensure efficient implementation of welfare schemes.
The Court held that Article 15(3) is an enabling constitutional provision intended to achieve substantive equality by permitting special measures for women and children. Such affirmative action cannot be treated as unconstitutional discrimination merely because it excludes men from certain categories of employment where the Government considers women to be better suited in public interest.
While examining Rule 22-A of the Telangana State and Subordinate Service Rules, the Court held that the proviso against total exclusion of men cannot be interpreted in isolation. The Rule itself empowers the Government to identify categories of posts where women are better suited and frame recruitment policies accordingly. Therefore, the proviso could not restrict the Government’s constitutional power exercised under Article 15(3).
The Court also distinguished the judgments relied upon by the petitioners. It observed that those cases concerned judicial officers and medical specialists, where both men and women were equally suited for the posts. In contrast, the present case related to the implementation of a specialised welfare programme dealing primarily with women and children. Consequently, those precedents were held to be factually inapplicable.
Instead, the Court relied upon the Supreme Court’s decision in Vijay Lakshmi v. Punjab University, which recognised the constitutional validity of special provisions for women made under Article 15(3). The Court observed that policy decisions of this nature, particularly those taken as preventive or precautionary measures for effective implementation of welfare schemes, ordinarily do not warrant judicial interference unless they are manifestly arbitrary or unconstitutional.
Finding no constitutional infirmity in the Government Order, the Court upheld the recruitment policy and dismissed both writ petitions. The judgment reinforces that Article 15(3) is a powerful constitutional tool enabling the State to adopt women-centric policies where such measures are reasonably connected with the objectives sought to be achieved, particularly in sectors involving the welfare of women and children.