Justice Meenakshi Madan Rai, the 48th Chief Justice of Patna High Court is superannuating after 11 years as judge on July 11, 2026. Before joining as the Chief Justice of Patna High Court on June 5, 2026, she was judge of Sikkim High Court. She was elevated as Judge, the Sikkim High Court on April 15, 2015. She was the first lady from Sikkim to be elevated to the post. She
She was the Acting Chief Justice of the Sikkim High Court on five occasions during July 2018 to January 2026. Before she arrived in Patna, there was a speculation that she is likely to be elevated as a judge of the Supreme Court. At present, there are only two women judges, namely, Justice B.V. Nagarathna and Justice V. Mohana, out 37 judges in the Supreme Court. The Court has strength of 38 judges.
The Chief Justice had authored first two judgements in Manju @ Manju Pandey vs. The State of Bihar and in Gautam vs. The State of Bihar on June 18, 2026 after joining the High Court on June 5, 2026 as part of the Division Bench which included Justice Soni Shrivastava.
In Manju"s case, as part of the Division Bench, in her 2-page long judgement, she concluded:"we are of the considered view that the instant petition cannot be entertained as a Public Interest Litigation and deserves to be dismissed and disposed of.6. The petition is accordingly dismissed and disposed of."
The petitioner from Gopalganj was aggrieved by Yoginda Devi, the Public Distribution System dealer, who who did not distribute consumer goods during the financial years 2010-2011, 2011-2012 and 2012-2013. She had alleged that on account of such non-distribution, widespread corruption has taken place. Yoginda Devi, the was appointed as a Public Distribution System dealer at Sihpur, Vijaipur from the first merit-list, issued by the authority to grant Public Distribution System License had submitted forged documents in connivance with the Appointment Committee and was not eligible to be a dealer. The counsel for the State submitted that the petitioner appeared to have a personal issue with Yoginda Devi, the dealer.
In Raj Gautam's case, the Chieg Justice had concluded that it is the prerogative of the Government to construct essential and necessary infrastructure which is required for official purposes on Government land.
Chief Justice Rai authored her last two judgements dated July 9, 2026 in The State of Bihar vs. Rohit Kumar and Surendra Jha vs. The State of Bihar.
Justice Arvind Singh Chandel's judgment in favour of Bihar State Special Survey Contractual Employees Association, upheld by Division Bench led by Chief Justice Rai against Revenue and Land Reforms Department, Land Records and Survey Directorate
In Rohit Kumar's case, Chief Justice Rai concluded in her 11-page long judgement dismissed the LPA. She upheld the impugned 11-page long judgment by Justice Arvind Single Chandel, the Single Judge dated April 22, 2025, in Rohit Kumar vs. The State of Bihar CW.J.C. No. 12384 of 2023 is accordingly upheld. But bearing in mind the lapse of time and the employment of the respondent/petitioner being contractual, the period of contract no longer survives, having lapsed on 31.03.2024, she observed:"In such circumstances, for the period from 19.03.2023 up to 31.03.2024, he cannot be reinstated, as ordered by the learned Single Judge. Consequently, it is ordered that he be paid his wages, without addition of any interest for the period 19.03.2023 to 31.03.2024, as that was the period of his then existing contract, which admittedly had been extended for two years from 01.04.2022 to 31.03.2024."
The other four respondents were: Additional Chief Secretary-cum-Appellate Authority, Revenue and Land Reforms Department, Government of Bihar, Director, Land Records and Survey Directorate, Revenue and Land Reforms Department, Government of Bihar, Assistant Director, Land Records and Survey Directorate, Revenue and Land Reforms Department, Government of Bihar and District Magistrate, Begusarai.
Notably, the Single Judge, while allowing the Writ Petition, had ordered the appellants/respondents to reinstate the services of the respondent/petitioner forthwith and issue necessary orders within two weeks from the date of receipt/production of a copy of the impugned Judgment. The appellants/respondents, however, were also afforded liberty to proceed against the respondent/petitioner, if so advised, in accordance with law.
The respondent’s/petitioner’s case was that pursuant to an advertisement issued in the year 2019, he was appointed as Special Survey Amin on March 31, 2020 by the Appellant/Respondent No. 3, Directorate of Land Records and Survey, Revenue and Land Reforms Department, Government of Bihar, on contractual basis, for a period of 11 months from the date of joining. The terms of the Appointment Letter stipulated that, a fresh contract would be issued after every 11 months, subject to satisfactory performance. The services of the respondent/petitioner were extended for the period April 1, 2022 to March 31, 2024. In the course of the discharge of his duties, on information allegedly received from the Settlement Officer, a show-cause notice, bearing Memo No. 535, dated January 18, 2023 was issued to the respondent/petitioner by the Assistant Director, Land Records and Survey Directorate, directing him to respond to the allegations of obstruction of the works of special survey since January 10, 2023 on the call given by the Bihar State Special Survey Contractual Employees Association and for having instigated other contractual employees to do the same. It is further averred that 500 other contractual employees also working as Special Survey Amins were issued the exact same notice on the same date. As required, he responded within 24 hours, on January 19, 2023, by email requesting inter alia that, the report of the Settlement Officer, Begusarai be furnished to him, to enable him to respond adequately.
Notably, given the paucity of time, the other contractual employees who also received the same show-cause notice, had furnished the exact same response as the respondent/petitioner, however the contract of the respondent/petitioner was terminated on January 19, 2023, for purported violation of Rule 8(4) of the “Bihar Special Survey Honorarium Based Contractual Employment Rules, 2019” while the other similarly situated employees were untouched.
The respondent/petitioner had appealed against the order of termination, before the Additional Chief Secretary, Revenue and Land Reforms Department, Government of Bihar, on January 24, 2023. The Appellate Authority, vide its order, dated 05.06.2023, rejected the appeal and upheld the order, dated January 19, 2023.
Being aggrieved, the respondent/petitioner approached the Writ Court, seeking quashing of the order of termination bearing Memo No. 1073, dated January 19, 2023, and the order bearing Memo No. 4704, dated June 5, 2023. He had also sought a direction for restoration of his contractual service of Special Survey Amin with consequential benefits.
The Single Judge had opined that more than 500 employees were issued identical show-cause notices on the same allegations as that of the respondent/petitioner and all had filed identical responses, but only the service of the respondent/petitioner was terminated, indicating the arbitrariness of the appellants/respondents.
Justice Chandel's decision in favour of Bihar State Special Survey Contractual Employees Association referred to decision in Anuj Shuckla vs. The BIADA & Ors.C.W.J.C. No. 18494 of 2024 which was based on the observations made by the Supreme Court in Dr. Vijaykumaran CPV vs. Central University of Kerala & Others (2020) 12 SCC 426 and Roop Singh Negi vs. Punjab National Bank and Others (2009) 2 SCC 570.
Justice Chandel had propounded that, when a stigmatic order of termination was issued against a contractual employee, it required a full-fledged departmental enquiry, where the show cause and defence taken by the employees should be considered and an appropriate opportunity of hearing should be extended to him. That, such opportunity was not afforded to the respondent/petitioner. The orders of termination were concluded to be stigmatic, thus both the impugned orders, dated January 19, 2023 and June 5, 2023 were set aside and the Writ Petition allowed with the directions.
The counsel for the State appellants/respondents, reiterated the facts before the Division Bench and contended that, after the respondent/petitioner was appointed as Special Survey Amin on March 31, 2020, his contract was extended for two years from April 1, 2022 to March 31, 2024 along with other similarly placed employees. The counsel submitted that the respondent/petitioner instigated the other contractual workers and obstructed the works of the special survey operation, consequent upon which show-cause notice dated January 18, 2023 was issued to him, which he responded to on January 19, 2023 denying the charges, but raised unrelated issues of non-payment and inadequate payments to contractual employees.
The judgement recorded that the respondent/petitioner failed to explain the obstruction charges and sought to justify the legitimacy of an unauthorized Association, resultant, his contractual employment was terminated on January 19, 2023, which was revelatory of the fact that he was singled out and discriminated against, which is in violation of Articles 14 and 16 of the Constitution of India. That, the impugned orders are not in consonance with Rule 8(4) of the “Bihar Special Survey Honorarium Based Contractual Employment Rules, 2019”, which requires the authority to provide an opportunity of hearing. It was further contended that as the principles of natural justice were not complied with, the orders dated 19.01.2023 and 05.06.2023 be quashed and his prayers be granted.
Chief Justice Rai observed:"11. So far as the conclusion of the learned Single Judge regarding the stigmatic order of termination is concerned, on careful perusal of the order, dated 19.01.2023, which is in Hindi and roughly translated into English reads as follows; “From the above facts, it is clear that he is unauthorizedly absent from his camp office and this act of his is indicative of total arbitrariness, causing hindrance in Government work, and defiance of orders of higher officials. The accused has created hindrances in the ambitious scheme of the Government, which is a time-bound programme. Along with this, other employees have also been provoked to disrupt work, which is contrary to the conduct of a qualified employee. Retaining such employee in service creates an adverse impact on other employees. Therefore, under the provisions described in Rule-8(4) of the “Bihar Special Survey Honorarium Based Contractual Employment Rules, 2019”, the contractual engagement of Shri Rohit Kumar, Special Survey Amin (AEN03112), is terminated with immediate effect”.
Chief Justice Rai observed:"it is clear that certain aspersions were cast on the respondent/petitioner,over and above the observations of his conduct. Hence, in our considered view, no error arises on the finding of the learned Single Judge regarding the observation that, when a stigmatic order of termination was passed against a contractual employee, it requires a full-fledged departmental enquiry, which in the instant case was denied to the respondent/petitioner. 13. In addition to the above, we are also of the considered view that, although 500 similarly situated employees had been issued show-cause notice on the exact same lines as the respondent/petitioner, and the 500 employees had also responded in the same language as the respondent/petitioner, blindsiding the similarity of their responses to that of the respondent/petitioner, they were afforded the privilege of continuing their contractual term until it was completed, however the services of the respondent/petitioner were terminated forthwith. Although, to augment and justify this circumstance, learned counsel for the appellants/respondents had argued that the contractual employment of the 500 employees were subsequently terminated, records reveal that such termination was on completion of their period of contract and not their services having been truncated before the period of contract was over."
The judgement of the Division Bench reads:" 14. In view of the foregoing observations, we are of the considered view that there is no reason to differ from the observations made by the learned Single Judge."
Division Bench ought not to interfere with Single Judge judgement "simply because an alternative view is possible", Justice Anil Kumar Sinha's judgement upheld
In her last 14-page long judgement as 48th Chief Justice of Patna High Court in The Chairman Bihar Industrial Area Development Authority & Ors. vs. Surendra Jha, Justice Rai concluded:"18. It is evident from a perusal of the catena of decisions referred to above, there are differing views regarding the percentage of back wages to be paid to the dismissed employee, who is reinstated and it can be culled out that the percentage of back wages to be paid in essentially left to the discretion of the Court, after it examines various factual circumstances of the case under consideration. There is no strait-jacket formula prescribed. A subjective view in such matters has therefore been permitted by the Judgments of the Hon’ble Supreme Court. 19. In view of the foregoing discussions, and considering the reasoned Judgment of the learned Single Judge, we do not find any ground to interfere with the findings therein, including the order of payment of 70 percent of back wages to the private appellant. 20. Needless to reiterate that, in a Letters Patent Appeal against a Single Judge’s order, interference is warranted only when the impugned Judgment suffers from a manifest error, patent illegality or perversity. Where the Single Judge has given a reasoned Judgment, the Division Bench ought not to interfere simply because an alternative view is possible."
Justice Anil Kumar Sinha was the Single Judge who had delivered the 13-page long judgement dated October 14, 2025.
The Division Bench which included Justice Soni Shrivastava dismissed both the appeals, namely, The Chairman Bihar Industrial Area Development Authority & Ors. vs. Surendra Jha and Surendra Jha vs. The State of Bihar & Ors. against Justice Sinha's judgement.
In effect, Justice Rai upheld the judgement by Justice Sinha who had grappled with the question as to whether the petitioner, whose compulsory retirement was quashed, is entitled to back wages for the intervening period from December 1, 2007 to July 3, 2014. He drew on Supreme Court's decision in Hindustan Tin Works Pvt. Ltd v. Employees of Hindustan Tin works Pvt.Ltd., reported in (1979) 2 SCC 80, wherein, it held that ordinarily, a workman, whose service has been illegally terminated, would be entitled to full back wages except to the extent he was gainfully employed during the enforced idleness. That is the normal rule. Any other view would be a premium on the unwarranted litigative activity of the employer. If the employer terminates the service illegally and the termination is motivated as in this case, viz., to resist the workman's demand for revision of wages, the termination may well amount to unfair labour practice. In such circumstances, reinstatement being the normal rule, it should be followed with full back wages.
Justice Sinha had relied on the decision in Deepali Gundu Surwase vs. Kranti Junior Adhyapak Mahavidyalaya, reported in (2013) 10 SCC 324, wherein, the Supreme Court has held that denial of back wages would amount to indirectly punishing the employee and rewarding the employer by relieving him of the obligation to pay back wages, whether employer wants to pat back wages or the employee is entitled to deny back wages or contest the employee’s entitlement to get consequential benefits, the employer has to plead and prove that employee was gainfully employed during the intervening period.
Justice Sinha referred to the decision of the Supreme Court, in Pradeepvs vs. Manganese Ore (India) Ltd., reported in (2022) 3 SCC 683, and also a 14-page long decision dated August 11, 2025 by Chief Justice Vipul M. Pancholi and Justice Partha Sarthy Division Bench of the Patna High Court, in The Bihar Industrial Area Development Authority Vs. Subhash Singh L.P.A. No. 317 of 2024. The Division Bench had upheld the 17-page long judgement dated January 15, 2024 by Justice Rajesh Kumar Verma who had set aside orders by BIADA, allowed the writ application is allowed and had directed BIADA to pay the arrears of salary of the petitioner within a period of three months.
Justice Sinha recorded that "the Managing Director as well as the Appellate Authority have denied back wages by relying on past service record and temporary nature of petitioner’s appointment. These grounds are unsustainable. Once the order of compulsory retirement was set aside, the alleged misconduct could not be the basis to deny consequential benefits, particularly in the absence of a lawful departmental enquiry establishing such misconduct. The reasoning that the petitioner was a temporary employee also does not impress this Court. The petitioner had rendered over 28 years of service, received time bound promotion and pay revision. To treat the petitioner as a temporary employee for denying back wages is arbitrary." He noted the employee, was illegally kept out of service, cannot be penalized for the employer’s own act of termination.
Justice Sinha had recollected that the Managing Director, BIADA, vide Memo No. 269, dated 10.11.2007, had imposed punishment of compulsory retirement to the petitioner with effect from 30.11.2007. The petitioner challenged the order of punishment of compulsory retirement in C.W.J.C. No. 9420 of 2008, which was allowed by the High Court on June 18, 2014 and the order of compulsory retirement was set aside. It was further directed to the respondents to resolve the grievance of the petitioner for payment of back wages in terms of the order, dated May 5, 2009, passed in CWJC No. 11196 of 2007, wherein reliance had been placed in the case of Novartis India Ltd. vs. State of West Bengal, reported in (2009) 3 SCC 124.
The order, dated June 18, 20214, passed in CWJC No. 9420 of 2008, the petitioner submitted a representation on November 3, 2014 seeking payment of back wages for the period of his compulsory retirement, i.e., from 01.12.2007 to 03.07.2014. However, the Managing Director, BIADA, vide Memo No. 6861, dated December 5, 2014, had rejected the claim of the petitioner for grant of back wages on the factually ground that (i) the petitioner was only a temporary employee; (ii) he had exhibited indiscipline; (iii) he was also in the habit of remaining on unauthorized absence; (iv) he had not averred anything regarding his gainful employment;and (v) the work during the absence of the petitioner, was performed by others who were duly paid and the authority could not be compelled to make double payment for the same period without any work performed by the petitioner.
Justice Sinha observed:"27.... a workman, whose service has been illegally terminated would be entitled to back wages except during the period of absence from duty. The order of compulsory retirement of the petitioner has been set aside by this Court and the matter was referred back to the Authority to take a decision on the issue of payment of back wages." He set aside the impugned orders, dated 05.12.2014 and 27.02.2017.
Justice Sinha concluded:"30. The BIADA is directed to pay 70 per cent of back wages to the petitioner for the period 01.12.2007 to 03.07.2014, in the entirety of the facts of this case. The payment shall be made to the petitioner within a period of four months from the date of receipt/production of a copy of this order. 31. In the result, this writ application is allowed." His judgement stands vindicated. Justice Rai has upheld his decision as part of Division Bench which included Justice Soni Shrivastava.
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