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2026 Supreme(Online)(Pat) 13873

IN THE HIGH COURT OF JUDICATURE AT PATNA
Harish Kumar, J
Madhav Raj (In- Person) – Appellant
Versus
The State of Bihar & Ors. – Respondent
Civil Writ Jurisdiction Case No.1142 of 2026



Advocates:
For the Appellants/Petitioners: Madhav Raj
For the Respondents: P.K. Verma, Sanjay Kumar Ghosarvey

The Court held that safety guidelines for female students in private hostels must include specific penalties for non-compliance to be effective and directed the State to implement these guidelines strictly and report on progress.

Headnote:(A) Women's Safety - Private Hostels/Lodges - Guidelines for registration, security infrastructure, and staff verification - Mandatory registration of hostels, installation of CCTV, and police verification of staff are essential to ensure a safe environment for female students. (Para 1)

(B) Administrative Law - Enforcement of Guidelines - Absence of penalty clauses - Guidelines issued for public safety are ineffective if they do not prescribe penalties or actions for non-compliance; necessity of incorporating punitive measures to ensure strict implementation. (Para 2, 5)

Issues: Whether the guidelines issued by the State for the safety of female students in private hostels are sufficient and how their implementation is being monitored.

Table of Content
1. establishment of safety and registration guidelines for girls' hostels. (Para 1)
2. necessity of penalty clauses and monitoring for effective implementation of safety guidelines. (Para 2 , 3 , 5)
3. procedural directions for status reporting and future hearing. (Para 6 , 7)

ORAL ORDER

(Per: HONOURABLE THE CHIEF JUSTICE)

6 24-04-2026 As per the previous order dated 10.04.2026, Mr. P.K.Verma, A.A.G-3 has produced the English translation of Circular dated 04.02.2026, contained in Memo No. 35/Pu.Mu.Ka, Vivadh-09/26, Bihar Police Mukhyalaya issued by Crime Investigation Department and Weaker Section Department by the Additional Director General of Police, Weaker Section with the approval of the Director General of Police in which it is stated as follows:-

“Memo 35/Pu Ma.Ka

Vividh-09/26

Bihar Police Mukhyalaya

Crime Investigation Department and

Weaker Section department

Dated 04.02.2026

To

All Senior Superintendents of

Police,

All Superintendents of Police

Bihar.

Subject:- Regarding the issue of

necessary consultation/guidelines

regarding the safety of female

students residing in girls hostels/lodges

operated under the state of Bihar.

In relation to the above-mentioned topic, it is said that in terms of the overall development of the society, it is necessary to be educated and self-reliant for girls/women, who are almost half of the population of the state. In the present, various schemes are being run by the government to educate girls/women. In the Indian constitution also girls/women have been given the right of equal opportunity and to live life with the dignity under Article 16 and Article 21 of the Constitution. As a result of the constitutional provisions and the efforts being made by the State government, women and girls have become aware of education, as a result, girls/women living away from their families for study in government or private hostels for higher education.

In the past few days, some instances have come to light that certain criminal incidents have occurred with the girls/women living in hostels/lodges for study. which requires the Government especially for the police to take necessary measures to prevent them. In order to advance girls/women in the field of education, it is imperative to provide them with a safe environment suitable for them.

Keeping in view the above mentioned facts, the following advisory/directions are given with reference to the operation of girls hostel/lodge for girls/women and the duty of the police in this regard.

1. Mandatory Registration and Verification

*Registration:- Management of every girls hostel/lodge running in the State should be advised that registration with the competent authority of their respective hostel/ lodges is mandatory. A register related to the respective operated girls hostel/lodge in each police station area should be compulsorily maintained in the police station-in which complete details of the respective hostel/lodge should be recorded. The responsibility of maintaining the said register should be handed over to the officer in charge of the Women's Help Desk working in the concerned police station

Police verification of staff: The warden of every hostel/lodge must be a woman who must be entered in the register maintained in the respective reporting station by doing police verification of all the employees including warden, guard, cook, cleaning staff working 24 X 7 in the hostel/ lodge.

2. Security infrastructure

*CCTV surveillance: High quality high resolution HD camera with voice recording facility should be definitely installed at the main entrance, corridor, dining area and premises of each hostel/lodge with option of at least 30 days to check whether the rooms are functional or not regularly by the in-charge of the respective women help desk and daily during the visit by the respective Abhaya brigade.

*Lighting:- Adequate lighting should be ensured on the stairs and in the corridors around the hostel/lodge. The Abhaya brigade in charge will ens

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