Are Anganwadi workers holders of a civil post?

No. The Supreme Court held they do not hold a civil post; they are community workers paid an honorarium.

Can Anganwadi workers file before an Administrative Tribunal?

No. Applications under Section 15 of the Administrative Tribunals Act are not maintainable for them.

Does the Minimum Wages Act apply to Anganwadi work?

Not unless the employment is listed in the Act’s Schedule. The Court said they are not entitled to minimum wages under the Act.

Are they government employees under Article 12?

Being under a State-controlled programme does not make them civil servants. Article 311 protections do not apply.

What else did the Court note?

It appreciated their social role but clarified they do not get the same legal benefits as government employees. They may contest elections.

State of Karnataka v. Ameerbi (2007) 11 SCC 681

Are Anganwadi workers government servants holding a civil post, and do minimum wages apply to them?

Citation: (2007) 11 SCC 681 Supreme Court Service / Social Welfare ~7 min read India

Author: Gulzar Hashmi Published: 23 Oct 2025 Keywords: Anganwadi, civil post, minimum wages, ICDS

Hero image for State of Karnataka v. Ameerbi case explainer

Quick Summary

Holding: Anganwadi workers are not holders of a civil post. They are community-based workers getting an honorarium under the ICDS scheme.

Minimum Wages Act applies only if the employment appears in its Schedule. Since Anganwadi work is not listed, statutory minimum wages do not apply. Applications before Administrative Tribunals are not maintainable.

Issues

Do Anganwadi workers hold a “civil post” under the State?
Does the State have to pay them minimum wages under the Minimum Wages Act, 1948?

Rules

Anganwadi workers do not hold a civil post; Sec. 15 applications before Administrative Tribunals are not maintainable.
Minimum Wages Act applies only to employments listed in its Schedule; otherwise, the State is not bound to pay minimum wages.
Not everyone under Article 12 becomes a government employee; Article 311 safeguards are not automatic.

Facts (Timeline)

Timeline: ICDS scheme, appointments, Tribunal view, Supreme Court appeal and decision

1975: ICDS scheme launched by the Centre; States implement it.

Appointments: Anganwadi workers selected locally by a committee; paid an honorarium.

Litigation: Some workers moved the Tribunal claiming civil-post status; single bench said no; larger bench said yes.

Appeal: State of Karnataka challenged before the Supreme Court.

Supreme Court: Held workers are not civil-post holders; Minimum Wages Act not applicable; Tribunal applications not maintainable.

Arguments

Appellant: State of Karnataka

Anganwadi is a scheme-based programme; posts are not statutory.
Workers are paid honorarium; not government servants under Article 311.
Minimum Wages Act applies only if listed; Anganwadi work is not.

Respondents: Anganwadi Workers

Work is controlled by the State; should be treated as civil-post holders.
Seek parity in protections, benefits, and minimum wages.
Tribunal should have jurisdiction given the nature of duties.

Judgment

The Supreme Court allowed the State’s appeal. Anganwadi workers are not civil-post holders; their applications before the Administrative Tribunal are not maintainable.

They are not entitled to minimum wages under the Minimum Wages Act since their employment is not in the Schedule. The Court recognised their valuable service but distinguished them from government employees.

Judgment visual: Supreme Court on Anganwadi workers’ status and wages

Ratio Decidendi

Scheme-based, honorarium-paid Anganwadi workers are community volunteers—not holders of civil posts. Minimum wages do not apply unless listed; Article 311 safeguards are inapplicable.

Why It Matters

Draws a clear line between scheme workers and civil servants.
Guides courts and departments on jurisdiction and benefits for ICDS staff.
Signals that better benefits need policy/legislative action, not judicial reclassification.

Key Takeaways

No civil-post status → no Article 311 protections; Tribunal route closed.
Minimum Wages Act applies only if employment is in the Schedule.
Social value acknowledged; legal status remains that of honorarium-based volunteers.

Mnemonic + 3-Step Hook

Mnemonic: “SCHEME ≠ SERVICE POST”

Identify: Is it a scheme post with honorarium?
Check: Is the job listed in the Minimum Wages Schedule?
Conclude: If scheme + not listed → no civil post, no MWA floor.

IRAC Outline

Issue	Rule	Application	Conclusion
Do Anganwadi workers hold a civil post under the State?	Posts must be statutory/regular; scheme roles with honorarium are not civil posts.	ICDS workers chosen locally, paid honorarium, not appointed to statutory posts.	Not civil-post holders; Tribunal jurisdiction fails.
Are they entitled to statutory minimum wages?	MWA applies only to employments in its Schedule.	Anganwadi work not listed.	No statutory minimum wages due.

Glossary

Civil Post: A regular, statutory government position carrying Article 311 protections.
Honorarium: A token payment for community service; not the same as salary.
ICDS: Integrated Child Development Services—nutrition, preschool, and health services scheme.

FAQs

No. They are scheme workers receiving an honorarium, not civil servants.

No. Article 311 applies to civil-post holders, which they are not.

Not under the Minimum Wages Act unless Anganwadi work is added to its Schedule.

Yes. Unlike civil servants, Anganwadi workers are permitted to contest elections.

Publication Details

CASE_TITLE: State of Karnataka v. Ameerbi, (2007) 11 SCC 681
PRIMARY_KEYWORDS: Anganwadi workers; civil post; Minimum Wages Act; ICDS; Administrative Tribunals Act
SECONDARY_KEYWORDS: Article 12; Article 311; honorarium; scheme employment; Tribunal jurisdiction