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2026 Supreme(Jhk) 514
IN THE HIGH COURT OF JHARKHAND AT RANCHI
M.S. Sonak, C.J., Rajesh Shankar, J.
Nageshwar Acharya - Petitioner
Versus
The State of Jharkhand through Chief Secretary - Respondents
W.P. (PIL) No. 682 of 2025
Decided On : 16-04-2026
For the Petitioner:Mr. Anupam Anand, Advocate Mr. Pranav Kumar, Advocate
For the Respondent: Mr. Piyush Chitresh, A.C. to A.G.
The right to life includes the right to health and safe working conditions. Industrial entities must provide adequate internal infrastructure to prevent the inequitable use of public resources and ensure compliance with statutory safety mandates under the constitutional framework.
Headnote:(A) Building Bye-laws - Rule 41 - Constitution of India - Articles 21, 39(e) and 42 - Right to health as a facet of right to life - Obligations of state and industries - Public interest litigation - Equitable use of public roads - Industrial liability for hazardous activities - Occupational safety and health care - Requirement for internal parking in industrial units - Disproportionate use of public road space for commercial interest - Regulation of industrial traffic. (Paras 1, 7, 8, 9, 11, 14, 15, 20, 23)
Facts of the case:
Petitioners brought a public interest litigation alleging that the absence of designated parking within an industrial plant forced heavy vehicles to use public roads, leading to congestion and accidents. Additionally, it was contended that the absence of nearby medical facilities deprived workers and the public of reasonable emergency health care, asserting a failure to fulfill service and safety obligations.
Findings of Court:
The court observed that the industrial entity failed to adhere to building regulations regarding on-site parking, causing obstruction to public thoroughfares. It further acknowledged the deficiency in emergency medical infrastructure for workers and the general public, emphasizing that the right to health is fundamental.
Issues: Whether the persistent omission by an industrial unit to provide necessary internal infrastructure justifies judicial intervention under public interest jurisdiction to enforce safety and health standards.
Ratio Decidendi: The state possesses a constitutional duty to ensure occupational health and safety in hazardous environments. Industrial units must maintain adequate internal facilities to prevent the exploitation of public resources or harm to the commuting public, as the right to health and safe passage are integral components of the right to life.
Result: Petition disposed of with specific directions for implementing parking compliance, road safety, and medical infrastructure improvements within defined timelines.
| Table of Content |
|---|
| 1. public interest petitions regarding industrial impact on citizens are maintainable. (Para 1 , 2 , 5) |
| 2. industrial entities have an implied duty to prevent hazardous operational negligence. (Para 3 , 4) |
| 3. right to health and safety is integral to article 21. (Para 6 , 7 , 8 , 9 , 10) |
| 4. industrial activity must ensure equitable use of public road infrastructure. (Para 11 , 12 , 13 , 14 , 15) |
| 5. state must enforce medical and traffic safety standards near hazardous industries. (Para 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23) |
| 6. judicial directives mandating compliance with statutory health and safety obligations. (Para 24 , 25 , 26) |
JUDGMENT :
M.S. Sonak, C.J.
1. The present writ petition has been filed in purported public interest seeking, inter alia, the following reliefs –
a. For issuance of an appropriate writ/ writs, order/ orders, direction/ directions particularly a writ in nature of mandamus commanding upon the Respondents to ensure that proper parking facilities are provided to the truck who are plying goods from and to Chaliyama Steel Plant, situated at Rajnagar, District- Saraikela Kharsawan operated by M/s Rungta Mines Limited in terms of the Rule 41 of Jharkhand Building Bye-laws, 2016 as there is no parking facility in available at the entry and exit gate of the said Steel Plant and public road is being used for by the trucks who are plying goods from and to Chaliyama Steel Plant and as such frequent road accident are taking place.
b. For issuance of an appropriate writ/ writs, order/ orders, direction/ directions particularly a writ in nature of mandamus commanding upon the Respondents to ensure that labours working at Chaliyama Steel Plant, situated at Rajnagar, District- Saraikela Kharsawan operated by M/s Rungta Mines Limited are provided with proper health care facilities which are accessible to them as they working in hazardous condition and nearest hospital to the said site is 12 (Twelve) Kilometres away at Chaibasa Sadar Hospital.
c. For issuance of an appropriate writ/ writs, order/ orders, direction/ directions particularly a writ in nature of mandamus commanding upon the Respondents to constitute a committee to investigate that the labours working at Chaliyama Steel Plant, situated at Rajnagar, District- Saraikela Kharsawan are provided with adequate health care, sanitation and wages in accordance with the laws and industry standard.
2. The above reliefs are sought in public interest litigation on behalf of the workers at the Chaliyama Steel Plant and commuters on the roads at Rajnagar in the district of Seraikella-Kharsawan.
3. The petitioners have alleged systemic operational negligence and persistent disregard for statutory mandates in the management and operation of the Chaliyama Steel Plant (CSP). They have alleged that on account of inadequate parking facilities and narrow roads in the region, heavy vehicles and trucks concerned with CSP utilize a disproportionate portion of the roads and stretches of the national highway in the region, creating serious hazards for the workers and commuters.
4. The petitioners have alleged that there are no adequate medical facilities either within the CSP or in its vicinity. They have alleged that on account of road accidents and other accidents related to non-compliance with safety regulations, the workers and the commuting public suffer. In the absence of medical facilities in the vicinity, such victims are often denied reasonable and adequate medical services. They have submitted that all these issues are of public interest and therefore the reliefs prayed for by them should be considered and granted.
5. The respondents have filed affidavits in this matter. They shall be discussed during this judgment and order. However, the respondents, in their affidavits, have pointed out the facilities already provided and have offered suggestions which would go a long way in addressing the issues raised by the petitioners in this petition.
6. The rival contentions, theref
