The court held that the provisions of the Maternity Benefit Act, 1961 prevail over the Financial Handbook.The Allahabad High Court (Lucknow Bench) has reiterated that maternity benefits granted under statutory law cannot be curtailed by executive instructions, holding that denial of maternity leave on the basis of provisions contained in the Financial Handbook is legally unsustainable when such provisions conflict with the Maternity Benefit Act, 1961.Justice Karunesh Singh Pawar granted the writ petition presented by a government employee and struck down the order denying the maternity leave and ordered the authorities to provide the leave along with all the services benefits on top of that, reinstating the primacy of the beneficial legislations over the administrative rules.Background of the CaseThe petitioner, Manisha Yadav, a Junior Assistant working at a Government Polytechnic in Barabanki, had applied for maternity leave for a period of 180 days from 06.04.2026 to 02.10.2026. Her application, however, was rejected by an order dated 04.04.2026.The rejection order, issued by the competent authority, stated that the leave was “not permissible” under Rule 153(1) of the Financial Handbook, without assigning any detailed reasons or examining the applicability of statutory provisions governing maternity benefits.Aggrieved by the rejection, the petitioner approached the High Court seeking quashing of the impugned order and a direction for grant of maternity leave in accordance with law.Petitioner’s SubmissionsOn behalf of the petitioner, it was argued that the issue was no longer res integra and had already been settled by multiple coordinate benches of the High Court.Reliance was placed on the decisions in Anupam Yadav v. State of U.P., Anshu Rani v. State of U.P., and Satakshi Mishra v. State of U.P., where it had been consistently held that the provisions of the Maternity Benefit Act, 1961 prevail over the Financial Handbook.It was argued that the rejection of maternity leave based solely on executive instructions, without considering the statutory mandate, was arbitrary and contrary to law. The petitioner stressed that maternity benefits are part of a beneficial legal framework intended to protect the dignity and health of working women, and cannot be denied on technical grounds.Stand of the StateThe State opposed the petition, relying upon Rule 153 of the Financial Handbook, which imposes certain conditions and restrictions on grant of maternity leave, including limitations in cases involving successive pregnancies within a specified period.It was argued that the petitioner’s case fell within the restrictions prescribed under the Financial Handbook and therefore the rejection of leave was justified.Court’s AnalysisThe Court examined the rival submissions in light of the binding precedents cited by the petitioner and found that the controversy had already been settled by earlier decisions of coordinate benches.Referring extensively to the judgment in Anupam Yadav, the Court noted that the State of Uttar Pradesh had, through various Government Orders, adopted the provisions of the Maternity Benefit Act, 1961 for its employees. Therefore, the statutory scheme under the 1961 Act would apply with full force.The Court reproduced and relied upon the following key observation:“The provisions of Financial Handbook are merely executive instructions and would be subsidiary to the legislation made by Parliament… in case of any inconsistency, the statutory enactment framed by the Parliament would prevail.”The Court further stressed that the Maternity Benefit Act is a beneficial legislation enacted to secure constitutional goals under Articles 38, 39, 42 and 43, as well as to give effect to Article 15(3), which enables the State to make special provisions for women.The Court reiterated:“Once the provisions of the Maternity Benefit Act, 1961 have been adopted by the State, the said Act would prevail over any inconsistent provision contained in executive instructions such as the Financial Handbook.”A significant aspect of the ruling was the Court’s affirmation that there is no statutory bar under the Maternity Benefit Act restricting grant of maternity leave for a second pregnancy within a specified time gap.The Court noted that the restriction imposed under Rule 153(1) of the Financial Handbook, which had been relied upon to deny leave, cannot override statutory entitlements.It was further observed that:“The rejection of maternity leave merely on the ground of executive instructions, without considering the statutory framework, reflects a manifest error.”The Court also took note of the fact that similar rejections had previously been set aside, and the legal position had been consistently clarified that second maternity leave cannot be denied solely on the basis of time-gap restrictions imposed by administrative rules.A central theme in the judgment was the clear distinction drawn between statutory rights and executive instructions.The Court held that while the Financial Handbook may regulate service conditions, it cannot curtail or override rights conferred by parliamentary legislation. Where a conflict arises, the statute must prevail.In reaffirming this principle, the Court underscored that maternity benefits are not merely service entitlements but statutory rights grounded in constitutional protections for women.The Court’s reasoning reinforces the broader legal position that executive instructions cannot dilute or restrict rights granted under a central legislation, particularly when such legislation is enacted to advance social welfare and gender justice.Applying the settled legal position to the facts of the present case, the Court found that the rejection of the petitioner’s maternity leave application was unsustainable.The impugned order had relied exclusively on the Financial Handbook without considering the overriding effect of the Maternity Benefit Act, 1961. There was no independent examination of the petitioner’s entitlement under the statutory framework.The Court held that such an approach was legally flawed and contrary to binding precedent.Final Directions of the CourtThe Court quashed the impugned order dated 04.04.2026 rejecting the petitioner’s maternity leave and issued a writ of mandamus directing the respondent authorities to grant maternity leave to the petitioner from 06.04.2026 to 02.10.2026 forthwith, along with all consequential service benefits, holding that the provisions of the Maternity Benefit Act, 1961 prevail over the Financial Handbook and that denial of maternity leave on the basis of executive instructions is impermissible in law.WRIT - A No. - 3721 of 2026Manisha Yadav vs State Of U.P. Thru. Addl. Chief Secy./ Prin. Secy., Deptt. Of Technical Edu. Lko. And AnotherDate of Decision: April 16, 2026Counsel for Petitioner(s) : Chinmay Mishra Counsel for Respondent(s) : C.S.C.(The author of this article, Vatsal Chandra is a Delhi-based Advocate practicing before the courts of Delhi NCR.)