LIC Employees Can Be Engaged As Enumerators & Supervisors For Census Duties: Allahabad High Court

The Allahabad High Court has observed that the employees of the Life Insurance Corporation of India (LIC) can legally be engaged as 'Enumerators' and 'Supervisors' for census duties.

A bench of Justice Dinesh Pathak thus dismissed a petition moved by 'North Central Zone Insurance Employees', an association of Class III and Class IV employees of the LIC, challenging the entrustment of census duties upon them

The bench conjointly read Section 4, 4-A, 6(1)(e), 7(c) of the Census Act, 1948, as well as Rule 3 of the Census Rules, 1990, to conclude that the staff of any establishment, including commercial entities such as the LIC, can be requisitioned for census duties.

It was the case of the petitioner-association that under Section 4-A of the 1948 Act, only the employees of 'local authorities' can be requisitioned for performing census duties as Enumerators/Supervisors.

It was further submitted that the employees of the LIC do not fall within the definition of "local authorities" as defined under Section 3(31) of the General Clauses Act, 1897; therefore, entrustment of census duties upon them is wholly unsustainable in the eyes of the law.

The Union of India, on the other hand, contended that Section 4-A of the 1948 Act cannot be read in isolation and has to be constructed conjointly with Section 6 (1)(e) and 7(c) of the 1948 Act, which specifically contemplate engagement of employees of factories, firms and establishments for census work.

It was argued that LIC comes within the ambit of a 'commercial establishment' and, therefore, engaging its staff for census operations is well within the domain of the Act, 1948.

It was further submitted that Rule 3 of the 1990 Rules prescribes the categories of eligible census officers, explicitly stating that an 'Enumerator' can be appointed from among 'teachers, clerks or any official or any person'.

Thus, it was contended, a wide discretion was conferred upon the competent authority to appoint suitable persons as Enumerators.

The bench, at the outset, noted that pursuant to a State Government Notification dated January 9, 2026, the Zonal Officer, in exercise of delegated power under Section 4(4) of the 1948 Act, read with Rule 3 of the 1990 Rules, issued orders appointing officials of the LIC as Enumerators and Supervisors.

The bench also referred to Section 6 of the 1948 Act, which empowers the authority to issue a written order directing the engagement of Managers/Officers of Railways, commercial and industrial establishments to perform the duties of census officers.

The bench noted that this provision allows the administration to enlist personnel from the corporate and industrial sectors for census work (e.g., enumerating employees, workers, or people on the premises).

It added that this reflects legislative intent to leverage the extension of the administrative hierarchy in the private sector for public duties during census operations.

The bench also referred to Section 7 of the Act, which empowers the authorised authority to issue a written order calling upon specific categories of persons to provide assistance for the census and such persons are bound to obey the order.

The Court pointed out that Section 7 is a broad, empowering provision that covers the private sector and allows the mobilisation of staff from companies for tasks such as enumeration, supervision, or data collection within their premises.

The bench further observed that the term 'establishment' is not narrowly restricted in the 1948 Act and is ordinarily understood to include organised bodies employing persons for official, commercial, industrial, educational, or administrative work and will include commercial establishments such as L.I.C.

The Court also took into account the tabulation appended to Rule 3 of the 1990 Rules. Against the designation of 'Enumerator' at Serial No. 5, the corresponding eligible categories include "teachers, clerks or any official or any person".

"The word "any person" employed in Column 2 against the designation "Enumerator" carries a wider connotation and cannot be confined only to the government employees or officials of the local authorities", the bench remarked as it noted that the Authorized Authority/Zonal Officer is competent to issued orders commanding the persons employed with the L.I.C. to act as Enumerators/Supervisors for census work.

The bench also relied upon the High Court's judgment in Life Insurance Corporation Of India vs Municipal Commissioner, Kanpur & Ors. 2011, wherein the engagement of LIC employees for census work was upheld.

Thus, the bench upheld the order passed by the Authorised Authority/Zonal Officer directing the employees of the LIC to discharge duties as Enumerators/Supervisors to facilitate census operations.

Further, the writ petition noted that the plea contained a vague prayer seeking the quashing of the decision to engage LIC employees for census work. In view of this, the bench dismissed the petition as being misconceived and devoid of merit.

Case title - North Central Zone Insurance Employees vs Union Of India And 5 Others 2026 LiveLaw (AB) 306

Citation: 2026 LiveLaw (AB) 306

Click Here To Read/Download Order