1. Total blockade of industrial plant gates by protesters causing restricted movement of employees, essential supplies, and potential threat to industrial safety and public order. (Para 2 , 3 , 11 )
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2026 Supreme(Jhk) 1338
IN THE HIGH COURT OF JHARKHAND AT RANCHI
SUJIT NARAYAN PRASAD, J.
Steel Authority of India Limited – Petitioner
Versus
The State of Jharkhand through Chief Secretary – Respondents
W.P.(Cr.) No. 639 of 2026
Decided On : 18-10-2026
Important Points
The court emphasized the critical duty of the district administration to maintain law and order to prevent industrial catastrophes in continuous process plants, accepting administrative undertakings to ensure unhindered access for employees and essential supplies.
Subject
Constitutional - Writ Petition
Act Referred
Headnote
(A) Writ Jurisdiction - Mandamus - Maintenance of Law and Order - Failure of district administration to prevent the blockade of industrial plant gates by agitators, posing a risk to life, property, and national economic loss. (Para 4, 11)
(B) Industrial Safety - Continuous Process Plant - Forced shutdown or blockade of essential supplies and manpower in a thermally sensitive plant can lead to catastrophic industrial human tragedy and equipment damage. (Para 3, 11)
(C) Administrative Undertaking - Court's reliance on the assurance and undertaking of the Deputy Commissioner to maintain law and order and ensure unhindered ingress and egress for employees. (Para 24, 27)
Issues: Whether the district administration failed in its duty to maintain law and order and ensure the smooth operation of the Bokaro Steel Plant by preventing illegal blockades.
(B) Industrial Safety - Continuous Process Plant - Forced shutdown or blockade of essential supplies and manpower in a thermally sensitive plant can lead to catastrophic industrial human tragedy and equipment damage. (Para 3, 11)
(C) Administrative Undertaking - Court's reliance on the assurance and undertaking of the Deputy Commissioner to maintain law and order and ensure unhindered ingress and egress for employees. (Para 24, 27)
Issues: Whether the district administration failed in its duty to maintain law and order and ensure the smooth operation of the Bokaro Steel Plant by preventing illegal blockades.
Legal Category Hierarchy
Advocates appeared:
For the Petitioner:Mr. Indrajit Sinha, Advocate [Through VC] Mr. Bibhash Sinha, Advocate Mr. Rishav Raj, Advocate
For the Respondents: Mr. Jai Prakash, AAC-IA
For the Petitioner:Mr. Indrajit Sinha, Advocate [Through VC] Mr. Bibhash Sinha, Advocate Mr. Rishav Raj, Advocate
For the Respondents: Mr. Jai Prakash, AAC-IA
Table of Contents
2. Petitioner sought state intervention to breach the blockade and protect industrial operations from harm, while respondents initially failed to act on reported grievances. (Para 4 , 11 )
3. The court emphasized the duty of district administration to ensure law and order, preventing industrial disruption and risks to public safety. (Para 17 , 18 , 24 , 26 )
4. Administrative authorities have a positive legal obligation to maintain public order and ensure unhindered industrial operations when there is an imminent threat to plant safety and life. (Para 24 , 26 )
5. The court secured an undertaking from the district administration to maintain unhindered access to the plant, deferred further orders, and directed the filing of compliance affidavits. (Para 27 , 28 , 29 , 30 )
6. What is the scope of the state's duty to maintain law and order for industrial operations under Article 226?
The state, through its district administration and police, is mandated to ensure that public peace is maintained and that essential industrial operations are not disrupted by unlawful blockades, thereby protecting life and property. (Para 4 , 17 , 18 , 24 )
7. Can private industrial concerns invoke writ jurisdiction when faced with illegal blockades threatening safety?
Yes, when administrative inaction to ensure law and order during a blockade poses an imminent threat to specialized industrial plant operations, property, and human life, the court may invoke jurisdiction under Article 226 to issue remedial directions. (Para 8 , 10 , 11 )
JUDGMENT
SUJIT NARAYAN PRASAD, J.
1. The instant writ petition has been notified for its hearing during ensuing Puja holidays. The Court is closed for Puja Holidays and is to reopen on 26.10.2026.
2. The background of notifying this case is that a letter has been sent by the learned counsel representing the Bokaro Steel Limited, a unit under the Steel Authority of India Limited by addressing the learned Registrar General of this Court that a situation of complete blockade has been created at all the gates of the Bokaro Steel Plant by the local MLA of Bokaro, along with agitators of the Visthapit Apprentice Sang (VAS). The situation was warranted due to their interruption caused in entry and exit of the employees, maintenance staff, raw materials, and essential supplies have been severely obstructed. These instances had created jeopardy in the continuous operation of the plant smoothly.
3. It has also been reported therein that the plant has never been shut down since its inception and that any forced shutdown, without the procedure of at least seven days, would risk the solidification of approximately 12,000 tons of molten steel in the blast furnaces, causing equipment damage running into thousands of crores of rupees, besides posing serious environmental hazards and potential threats to human life. It has also been pointed out that several portions of the plant constitute a restricted/protected area under the Bihar Gazette Notification dated 13.10.1969 and Section 2 of the Official Secrets Act, 1923.
4. The grievance of the writ petition is that even though the representation was made by the SAIL/BSL to the District Administration, Chas, Bokaro on 15.10.2026 but the same has remain unattended. The police and the local administration have failed to discharge their duty to maintain law and order.
5. The learned Registrar General of this Court, immediately after receipt of the said communication from Mr. Indrajit Sinha learned counsel representing the writ petitioner, has brought the same to the notice of the Hon’ble the Chief Justice by making out three proposals for consideration of the Hon’ble The Chief Justice.
6. The Hon’ble the Chief Justice has directed the learned Registrar General of this Court to constitute a Bench so that the appropriate consideration on the grievance of the content of the representation so made by the learned counsel representing the SAIL/BSL be made, thereby, the present Bench has been constituted by notifying the case for its hearing at 02:15 p.m.
7. The minutes of assignment is available on record along with approval received by the learned Registrar General of Hon’ble the Chief through WhatsApp.
8. The jurisdiction of this Court as conferred under Article 226 of the Constitution of India has been invoked.
9. Initially, the case was having the filing no.25204 of 2026 but subsequently, the present case has been instituted as W.P.(Cr.) No.639 of 2026 by impleading the following parties as respondent to the proceeding:
1. The State of Jharkhand through Chief Secretary, having its office at Project Building, Dhurwa, P.O. Dhurwa, P.S.Jagannathpur, District Ranchi.
2. Deputy Commissioner, Bokaro, having its office Bokaro Collectorate, P.O. & P.S. Bokaro Steel City, District Bokaro, Jharkhand.
3. Sub Divisional Magistrate, Chas Bokaro, having its office Chas, P.O. & P.S. Chas, District Bokaro, Jharkhand.
4. Superintendent of Police, Bokaro, having its office at Bokaro, P.O. & P.S. Bokaro Steel City, District Bokaro, Jharkhand.
5. Officer-in-Charge, B.S. City Police Station having its office at B.S. City, P.O. & P.S. B.S. City, District Bokaro, Jharkhand.
6. Officer-in-Charge Marafari Police Station, having its office Marafari, P.O. & P.S. Marafari, District Bokaro, Jharkhand.
7. Officer-in-Charge Harla Police Station, having its office Harla, P.O. & P.S. Harla, District Bokaro, Jharkhand.
8. Officer-in-Charge Sector-IV Police Station Bokaro, having its office Sector-IV, Bokaro, P.O. & P.S. Sector-IV, District Bokaro, Jhar
