News Citation : 2026 LN (HC) 199 | 2026:CGHC:12558-DB

March 16, 2026 : The Chhattisgarh High Court has dismissed an appeal filed by a Raipur resident seeking financial assistance under the Lok Nayak Jai Prakash Narayan Samman Nidhi Scheme, ruling that the applicant failed to meet the eligibility criteria due to alleged criminal antecedents.

A Division Bench comprising Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal delivered the judgment while hearing a writ appeal filed by Ramgulam Singh Thakur, who had challenged the dismissal of his earlier writ petition by a single judge of the court.

The appellant had approached the court seeking the release of Samman Nidhi benefits under the Lok Nayak Jai Prakash Narayan (MISA/DIR Rajnaitik Ya Samajik Karno Se Niruddha Vyakti) Samman Nidhi Niyam, 2008. He also sought interest on the delayed payment and questioned the legality of the expression “Rajnaitik ya Samajik Karno Se Niruddha Vyakti” used in the scheme’s rules.

According to the appellant, he was a student leader and socio-political activist who had participated in farmers’ protests against the state government’s levy policy during the mid-1970s. During the Emergency declared on 25 June 1975, he was arrested and detained under the Maintenance of Internal Security Act (MISA). Court records show that he remained lodged in Raipur Central Jail from 31 August 1975 to 10 January 1977.

After the Chhattisgarh government introduced the Samman Nidhi scheme in 2008 to provide financial assistance to individuals detained under MISA or DIR during the Emergency, the appellant applied for benefits in March 2009. However, his claim was rejected by the Raipur Collector in May 2010 on the basis of a police report stating that several criminal cases had been registered against him.

The rejection was later upheld by a committee constituted under the 2008 Rules, which concluded that he did not satisfy the scheme’s eligibility conditions. Rule 6 of the scheme requires that beneficiaries must have been detained solely for political or social reasons and must not have criminal antecedents or involvement in anti-social activities.

During the appeal proceedings, the state government submitted an affidavit stating that as many as 32 criminal cases of a criminal or anti-social nature were registered against the appellant between 1974 and 1986 across various police stations in Chhattisgarh. Authorities also reported that his name currently appears on a police surveillance list.

The appellant contested these claims, arguing that the alleged cases were either unrelated to his Emergency-era detention or that the records had been destroyed or were unavailable. He also maintained that no criminal conviction had been recorded against him and that he fulfilled all the conditions required under the scheme.

However, the High Court found that the appellant had not directly challenged the decision of the committee that rejected his claim. Instead, he had only challenged the communication issued by the Collector informing him about the rejection. The court held that without challenging the committee’s decision itself, the writ petition was not maintainable.

The bench further observed that the determination of eligibility under the Samman Nidhi scheme rests with the statutory committee constituted under the 2008 Rules. Since the committee had already concluded that the appellant did not meet the criteria due to his alleged criminal record, the court found no reason to interfere with the decision.

Addressing the argument that the wording used in the scheme rules was inconsistent with the provisions of MISA, the court declined to examine the broader constitutional validity of the rules in the present appeal, noting that the case primarily concerned the rejection of the appellant’s claim for financial assistance.

Concluding that no legal error or violation of natural justice had been shown in the earlier judgment, the High Court dismissed the writ appeal and upheld the rejection of the Samman Nidhi claim.

Case Reference : WA No. 752 of 2024, Ramgulam Singh Thakur vs State of Chhattisgarh & Another; Counsel for Appellant: Mr. Manoj Kumar Dubey, Advocate; Counsel for State/Respondents: Mr. Shashank Thakur, Additional Advocate General.