MANISHA RAVINDRA PANPATIL versus THE STATE OF MAHARASHTRA & ORS.
[2024] 9 S.C.R. 770, Supreme Court of India, 2024
Outcome: Appeal(s) allowed (Granted)
Segment: Issues
[2024] 9 S.C.R. 770 : 2024 INSC 762
Manisha Ravindra Panpatil 
v. 
The State of Maharashtra & Ors.
(Civil Appeal No. 10913 of 2024)
27 September 2024
[Surya Kant and Ujjal Bhuyan, JJ.]
Issue for Consideration
Appellant-Sarpanch was removed from office on the allegations 
of encroachment of government land by her. Whether the 
disqualification of the appellant was justified.
Headnotes†
Women representatives in elected bodies – Prejudicial 
treatment at all levels of administrative functioning, 
deprecated – Allegations made by the private respondents as 
regards encroachment of government land by the appellant, a 
female Sarpanch – Mechanical orders passed by authorities, 
appellant removed from office – Removal affirmed by High 
Court – Justification:
Held: There is no credible and convincing material on record to 
substantiate the allegations of encroachment of government land 
by the appellant before or post her election as Sarpanch – Nature 
of allegations and the consequential removal from the office of 
Sarpanch, highly disproportionate – Matter of removal of an elected 
public representative should not be treated so lightly, especially 
when it concerns women belonging to rural areas – Impugned 
order set aside – Appellant to continue and perform the duties of 
Sarpanch of the Gram Panchayat till the completion of her tenure. 
[Paras 10-12]
List of Keywords
Sarpanch; Women representatives; Female Sarpanch; 
Disqualification; Removal from office; Private respondents; No
professional misconduct; Encroachment of government land; 
Punishment disproportionate; Mechanical/summary orders; Women 
empowerment.
[2024] 9 S.C.R. 
771
Manisha Ravindra Panpatil v. The State of Maharashtra & Ors.
Case Arising From
CIVIL APPELLATE JURISDICTION: Civil Appeal No. 10913 of 2024
From the Judgment and Order dated 03.08.2023 of the High Court 
of Judicature at Bombay at Aurangabad in WP No. 4577 of 2023
Appearances for Parties
Sudhanshu S. Choudhari, Sr. Adv., Vatsalya Vigya, Ms. Gautami 
Yadav, Ms. Pranjal Chapalgaonkar, Ms. Sapna Sinha, Akshay 
Sinha, Advs. for the Appellant.
Prashant Shrikant Kenjale, Shrirang B. Varma, Siddharth 
Dharmadhikari, Aaditya Aniruddha Pande, Bharat Bagla, Sourav 
Singh, Aditya Krishna, Ms. Preet S. Phanse, Adarsh Dubey, Advs. 
for the Respondents.
Judgment / Order of the Supreme Court
Order
1.	
Leave granted.
2.	
Heard learned counsel for the parties.
3.	
The appellant is an elected Sarpanch of Gram Panchayat, Vichkheda 
situated in Jalgaon District of Maharashtra. She contested in 
the panchayat elections and won in February, 2021. A dispute 
subsequently arose between the appellant and respondent nos. 5 
to 7 (hereinafter referred as ‘the private respondents’), who sought 
her disqualification on the ground that she was allegedly residing 
with her mother-in-law in a house erected upon government land. 
The appellant however, had vehemently contended that she does not 
reside in that particular dwelling, and that she lives separately with 
her husband and children in a rented accommodation. She further 
contended that the concerned dwelling was in such a
dilapidated 
condition that it could not be inhabited. 
4.	
However, without appropriately verifying these factual issues and 
on the basis of bald statements, the concerned Collector passed 
an order disqualifying the appellant from continuing as Sarpanch. 
This order was thereafter confirmed by the Divisional Commissioner. 
Subsequently, the High Court vide the impugned order, dismissed
772
[2024] 9 S.C.R.
Digital Supreme Court Reports
the appellant’s writ petition against the Commissioner’s order on a 
technical ground, thus putting a seal of approval on her removal 
from office. 
5.	
This seems to us a classic case where the residents of the village 
could not reconcile with the fact that the appellant, being a woman, 
was nevertheless elected to the office of the Sarpanch of their village. 
They were perhaps further unable to come to terms with the reality 
that a female Sarpanch would make decisions on their behalf de 
jure and that they would have to abide by her directions. 
6.	
It is patently obvious that these were the primary motivations which 
led the private respondents to initiate their orchestrated efforts 
towards the removal of the appellant, from her duly elected position. 
Having found no instance of professional misconduct on the part of 
the appellant that they could etch away at, the private respondents 
instead embarked on a mission to cast aspersions upon the appellant, 
by any means necessary. This initiative was undertaken by them, 
with the intention of securing her removal from public office.
7.	
Though the private respondents grasped at straws in their bid to evict 
the appellant from her position, their cause was perhaps aided by the 
mechanical and summary orders passed by government authorities, 
at various levels. These orders were passed in a lackadaisical 
manner, without making any effort towards conducting a fact-finding
exercise, so as to confirm whether the allegations levied by the 
private respondents were sufficiently made out. There is nothing on 
record to suggest that any objection of the appellant’s family having 
encroached upon government land was ever raised when she filed 
her nomination papers. 
8.	
At this juncture, we would like to note that the vagaries of the present 
factual matrix is far from unique and is unfortunately somewhat 
of a norm. While there is no doubt in our mind that the private 
respondents may have operated in a discriminatory manner, what 
is more worrying is the casual approach adopted by government 
authorities in summarily removing an elected representative. This 
is all the more concerning when the representative in question is 
a woman and elected in the reservation quota, thereby indicating 
a systemic pattern of prejudicial treatment, permeating through all 
levels of administrative functioning.
[2024] 9 S.C.R. 
773
Manisha Ravindra Panpatil v. The State of Maharashtra & Ors.
9.	
This scenario gets further exacerbated when we as a country are 
attempting realize the progressive goal of gender parity and women 
empowerment across all spheres, including public offices and most 
importantly adequate women representative in the elected bodies, 
such instances at the grass-root level cast a heavy shadow on any 
headway that we may have achieved.
10.	 That being said and having regard to the facts and circumstances 
of the case at hand, we see no credible and convincing material 
on record to substantiate the private respondents’ allegations of 
encroachment of government land by the appellant before or post 
her election as Sarpanch. All that we would like to reiterate is that 
the matter of removal of an elected public representative should not 
be treated so lightly, especially when it concerns women belonging to 
rural areas. It must be acknowledged that these women who succeed 
in occupying such public offices, do so only after significant struggle. 
11.	 In this vein, the concerned authorities need to sensitize themselves 
and work towards creating a more congenial atmosphere where 
women, such as the appellant, can prove their worth by rendering 
their services as Sarpanch of the Gram Panchayat.
12.	 In our considered view, the nature of allegations and the consequential 
punishment awarded to the appellant, namely, her removal from the 
office of Sarpanch, is
highly disproportionate. 
13.	 For the reasons afore-stated, the appeal is allowed. The impugned 
order dated 03.08.2023 passed by the High Court is set aside. The 
appellant, in whose favour stay had already been granted, shall be 
allowed to continue and perform the duties of Sarpanch of the Gram 
Panchayat till the completion of her tenure.
14.	 Ordered accordingly.
Result of the Case: Appeal allowed.
†Headnotes prepared by: Divya Pandey