State Must Honour Jyoti Yojna Promise to Women Who Underwent Sterilisation on Its Assurance: Rajasthan High Court

A circular of 19.08.2011 introduced the ‘Jyoti Yojna’ for women with one or two daughters who underwent sterilisation, promising free education up to post-graduation, free nursing courses, preference in selection as Asha Sahayogini, ANM and GNM, and free treatment in government hospitals (para 7). The petitioner, who had one daughter, was sterilised on 16.07.2012 and received a Jyoti Card on 26.01.2013 (para 9). She then studied from Class X to the GNM course at her own cost; her claims, forwarded to the Director in 2015, went unanswered (para 9). The State said the scheme was closed in the 2015-16 budget and a U.T.I. bond had been issued to her daughter under another scheme (paras 5, 10).

The Court held that by relying on the circular and undergoing sterilisation, the petitioner acquired a legitimate expectation that the Government would keep its promise, including meeting her education expenses (paras 12-13). Estoppel prevents a party from going back on its word when another has relied on it to her detriment; having altered her circumstances significantly, she could not now be denied the benefits (paras 14-15). Tracing the doctrine to the rule of law and Article 14's insistence on non-arbitrariness, the Court noted that a claimant must show reliance and resulting detriment, and that a court may interfere where the authority's decision is arbitrary, unreasonable, an abuse of power or contrary to natural justice (paras 16-18). It relied on National Buildings Construction Corporation v. S. Raghunathan, which requires reliance and detriment as for promissory estoppel, and referred to Official Liquidator v. Dayanand and Schmidt (paras 18-20). As the State had issued her a Jyoti Card and then closed the scheme in 2016, its refusal was against public interest, arbitrary and a breach of promise violating legitimate expectation and promissory estoppel (paras 22-23).