THE PRINCIPAL SECRETARY TO GOVERNMENT V. S.CHITRA WA NO.3866 OF 2025:

DATE: 19/02/2026

COURT: High Court of Madras

BENCH: Chief Justice Manindra Mohan Shrivastava and Justice G. Arul Murugan

FACTS:

The Moovalur Ramamirtham Ammaiyar Ninaivu Marriage Assistance Scheme was introduced by the State government to provide financial aid to girls during marriage, with eligibility restricted to applicants whose family income did not exceed Rs. 6,000 per month (Rs. 72,000 per year). The first respondent, a writ petitioner, applied for benefits under this scheme but her claim was rejected by authorities based on an income certificate issued by the Zonal Deputy Tahsildar, which assessed her annual income at Rs. 1,08,000 (averaging Rs. 9,000 per month), rendering her ineligible. Despite opportunities to appear or engage counsel, the first respondent did not participate in the subsequent appeal proceedings before the Division Bench.

The writ petition filed by the first respondent challenged the rejection of her individual claim, asserting that her actual earnings were only Rs. 6,000 per month regardless of the certificate. The learned Single Judge, while examining the merits, went beyond the petition's scope and directed that the scheme's benefits be extended to all individuals earning equivalent to or less than the prevailing minimum wages under the Minimum Wages Act. This order was assailed in appeal (WA No. 3866 of 2025) by the State government, represented by the Advocate General, who argued that the Single Judge had impermissibly altered the executive policy without any challenge to its validity or a broader prayer for expansion.

ISSUES:

The primary issues in this case revolved around whether the rejection of the first respondent's marriage assistance claim was justified based on the income certificate showing earnings above the Rs. 6,000 monthly threshold, and whether the Single Judge's directive to extend scheme benefits to those earning minimum wages exceeded the limited scope of the writ petition, which sought only review of the individual rejection without challenging the policy's income criteria or seeking its modification for a larger class.

JUDGEMENT WITH REASONING:

In its judgement, the Division Bench allowed the State's appeal, set aside the Single Judge's order, and disposed of the writ petition with a limited observation: if the first respondent could obtain a modified income certificate through fresh inquiry proving her earnings were below Rs. 6,000 per month during the scheme's operation, she would be entitled to benefits, but this direction applied solely to her case and not as a general policy expansion. No costs were imposed, and the connected miscellaneous petition was closed.

The court's reasoning emphasized the narrow confines of the writ petition, which solely contested the rejection of the first respondent's individual claim and did not include any prayer to challenge or amend the scheme's income eligibility criteria. The Single Judge's expansion of relief to encompass all minimum wage earners constituted an overreach, as no material evidence was presented to impugn the validity of the income certificate issued by the Zonal Deputy Tahsildar. Absent a successful challenge to the certificate's accuracy, the only feasible judicial remedy would have been a direction for fresh inquiry into the respondent's income, not a wholesale policy revision. This approach ensured that judicial intervention remained tethered to the pleaded relief, preventing courts from venturing into legislative or executive domains without explicit grounds, such as constitutional violations, which were neither raised nor substantiated here.

Furthermore, the judgement underscored the settled principle of limited judicial review over executive policies, which can only be altered through permissible challenges on grounds of illegality or unconstitutionality, not mere comparative equity like benchmarking against minimum wages. The Single Judge's comparison lacked legal foundation, as no such mandate exists under any statute requiring marriage assistance to align with minimum wage notifications, rendering the directive an impermissible substitution of one policy for another. The court noted the scheme's discontinuation on 02.08.2022 as an additional factor reinforcing non-interference, while carving out a case-specific safeguard for potential re-verification to uphold natural justice without broader implications, thereby balancing individual equity with institutional restraint under Article 226 of the Constitution.

ANALYSIS:

The Division Bench of the Madras High Court delivered a significant ruling reinforcing the separation of powers in the context of welfare schemes. The court overturned the Single Judge's order that had expanded the eligibility under the Moovalur Ramamirtham Ammaiyar Ninaivu Marriage Assistance Scheme (commonly known as Thalikku Thangam) from the fixed income cap of Rs. 6,000 per month to all those earning up to the prevailing minimum wages. This decision underscores that judicial review under Article 226 is confined to examining the legality of administrative actions in individual cases, not to redesigning or broadening executive policies absent a direct constitutional challenge or statutory violation. By setting aside the expansive directive, the Bench prevented courts from encroaching on policy-making domains reserved for the executive, emphasizing that welfare benefits like marriage assistance, being discretionary executive largesse rather than a fundamental or statutory right cannot be judicially rewritten based on notions of equity or comparison with other laws such as the Minimum Wages Act.

The judgement also reflects pragmatic judicial restraint in light of evolving state priorities, noting the scheme's discontinuation from August 2, 2022, and its restructuring into the Moovalur Ramamirtham Ammaiyar Higher Education Assurance Scheme. While upholding the original income criterion and rejecting blanket expansion, the court balanced this by allowing a narrow, case-specific remedy: permitting the writ petitioner (a domestic worker whose claim was rejected due to an income certificate showing Rs. 9,000 monthly average) to seek fresh verification of her income during the scheme's active period. This limited direction safeguards individual justice without setting a precedent for wider policy alteration, illustrating how courts can uphold administrative decisions while protecting against potential errors in fact-finding processes like income certification. Overall, the ruling serves as a reminder that executive policies, even benevolent ones, enjoy wide latitude unless they infringe fundamental rights or legal norms, thereby preserving institutional boundaries in India's constitutional framework.