The Allahabad High Court has ruled that employees of the Life Insurance Corporation of India (LIC) can legally be appointed to duties as Enumerators/Supervisors for census activities.
Rejecting the challenge raised by an employees’ union, the Court observed that the Census Act, 1948, and the Census Rules, 1990, permit the engagement of employees from establishments such as LIC for census work.
The Court emphasized that “The expression ‘any official or any person’ employed in Rule 3 is of wide amplitude and cannot be restricted only to employees of local authorities or government departments.”
It further noted that “once appointed for census work, such persons are deemed to be public servants and are under a statutory obligation to discharge the assigned duties.”
The judgment was given by Single Bench of Justice Dinesh Pathak in a writ petition filed by the North Central Zone Insurance Employees, which represents Class III and Class IV employees of LIC in the corporation’s North Central Zone headquartered in Kanpur.
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In the petition, the association/petitoner had sought to restrain authorities from assigning census duties to LIC staff, arguing that Section 4-A of the Census Act, 1948 contemplates requisitioning only the staff of local authorities for census-related work.
According to the petitioners, LIC does not fall within the definition of a local authority, and therefore its employees could not be compelled to participate in census operations.
Reliance was placed on decisions of the Punjab and Haryana High Court in Life Insurance Corporation of India vs. Union of India And Others, C.W.P. No.7037 of 2010, and the Gujarat High Court in Life Insurance Corporation Ltd. vs. Registrar General and Census Commissioner of India; Special Civil Appeal No.5335 of 2010, which, it was contended that the statutory power could not be stretched to cover employees of public sector corporations.
The counsel for the Union of India opposed the plea, and contended that the Section 4-A of the Act, 1948 cannot be read in isolation, but it has to be read conjointly with Sections 6 (1)(e) and 7(c), which in particular consider engagement of employees of factories, firms and establishments for census work.
Further, the respondent has emphasized that the L.I.C. comes within the scope of a ‘commercial establishment’ and, therefore, engaged of the staff for census duties is well within the sphere of the Act, 1948.
Considerably, it was opposed by the respondent that the order of the Zonal Officer as passed under Section 4(4) whereby employees of the L.I.C. are assigned as Enumerators/Supervisors, has not been challenged by the petitioner in the instant writ petition.
After examining the statutory scheme, the High Court agreed with the Union government’s argument.
The Court noted that Rule 3 of the Census Rules, 1990 authorises the appointment of Enumerators from among “teachers, clerks or any official or any person.”
Significantly, the rule does not distinguish between employees of government departments and those working in commercial or institutional establishments.
The expression employed by the rule-making authority, the Court said, is deliberately expansive.
The Bench observed that a combined reading of Sections 4, 4-A, 6(1)(e) and 7(c) of the Census Act leaves little scope for doubt that employees of establishments can lawfully be called upon to assist in census operations.
The judgment notes that these provisions were designed to strengthen the administrative machinery required for a nationwide exercise of enormous scale and to enable authorities to utilize both governmental and institutional resources.
The Court also placed reliance on an earlier Division Bench decision of the Allahabad High Court in Life Insurance Corporation of India And Others vs. Municipal Commissioner/Additional Chief Census Officer, Nagar Nigam, Kanpur And Others, Civil Misc. Writ Petition No.28736 of 2010., which had upheld the requirement of LIC personnel for census work.
In that case, the Bench had held that LIC employees fall within the expression “establishment” and can therefore be required to assist in the census process.
While recognizing the power of authorities to requisition staff, the earlier ruling had advised that only the minimum necessary workforce should be drawn so that the functioning of institutions is not unduly disrupted.
Taking note of the notification issued by the State government dated 04.02.2026, scheduling the first phase of Census of India, 2027 between 22.05.2026 to 20.06.2026, the Court found no error or illegality in the orders issued by the competent authority appointing LIC employees as Enumerators/Supervisors.
Besides this, the court also observed that the writ petitioner did not challenge any specific appointment order and instead sought a writ of mandamus for prohibition against engaging LIC personnel in census work.
Accordingly, the court concluded that the challenge could not be sustainable in law, as it was contrary to the statutory provisions governing census operations, and thus, dismissed the writ petition.
Case: North Central Zone Insurance Employees vs Union Of India And 5 Others
Case No: Writ – A No. – 7210 of 2026
Date of Order: 29.05.2026
Status: Dismissed
