Safiya Malik

The High Court of Rajasthan Single Bench of Justice Anoop Kumar Dhand has taken suo motu cognizance of the collapse of a Government Upper Primary School classroom ceiling and wall in Village Piplodi, District Banswara. The Court directed the Union of India, the State of Rajasthan, and relevant departments to submit compliance reports regarding school safety and infrastructure standards across the state. The tragedy, which occurred on 25 July 2025, resulted in the loss of seven young lives and left several others critically injured.

Treating the matter as a public interest litigation concerning the safety and well-being of school-going children, the Court issued a detailed 14-point set of proposed directions addressing structural, sanitary, technological, and administrative deficiencies in educational institutions. The Court ordered issuance of show cause notices to the Union and State authorities, including the National Commission for Protection of Child Rights (NCPCR), and summoned a report from the Chief Secretary of Rajasthan and the Ministry of Education and Child Development. The matter is listed for hearing on 01 August 2025. The directive mandates a systemic overhaul of school infrastructure and states the constitutional obligation to ensure children receive education in a safe and dignified environment.

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The incident prompting this judicial intervention took place on 25 July 2025 in a Government Upper Primary School located in Village Piplodi, District Banswara. The ceiling and wall of a classroom collapsed during school hours, causing the tragic death of seven children, including two siblings. Several other students sustained grievous injuries and are currently undergoing medical treatment. The incident was widely reported across electronic, print, and social media platforms, leading to public outrage and grave concern.

In response to this disturbing event, Justice Anoop Kumar Dhand took suo motu cognizance and registered a public interest litigation to address the broader issue of school safety and infrastructural deficiencies.

The Court cited findings from the National Commission for Protection of Child Rights (NCPCR) which conducted a survey covering over 26,000 schools in 12 states, including Rajasthan. The report found that "approximately 22% of operational school buildings are in a dilapidated condition" and "around 31% of schools were found to have structural cracks, raising serious concerns about the safety and security of children studying in these buildings."

The Unified District Information System for Education (UDISE) data revealed that despite 6% of Rajasthan's total budget being allocated to education, infrastructural development remains grossly inadequate. The report states that "in 32% of these schools, there is no electricity connection, forcing children to study under extreme heat conditions." Over 50% of primary schools reportedly operate without electricity.

Further deficiencies include lack of drinking water and sanitation facilities. "9% of the Government Schools in State lack functional drinking water facilities," the Court noted. Approximately 9% of Government Schools also do not have boys’ toilets, and 10% lack toilets for girls.

Medical consequences of these conditions were also stated. The Court recorded that "deferring urination can lead to Urinary Tract Infections (UTIs), distended bladders, and various gynecological problems" among girl students. Moreover, "lack of sanitary protection and absence of toilets... significantly increases the risk of toxic shock syndrome."

Access to free sanitary pads remains limited, contributing to absenteeism and poor academic performance among girls. Library and digital infrastructure is also substandard. While 74% of schools reportedly have libraries, "students often complain that these are merely small rooms, poorly equipped with few books." Only 30% of schools have computer access, with just 24% having functional internet connectivity.

On a national level, data from UDISE+ indicated that "out of the 14.71 lakh schools in India, 1.52 lakh schools still operate without functional electricity." Government schools are particularly affected, with "only 9.12 lakh out of 10.17 lakh having functional electricity." Private schools, by contrast, show better infrastructure.

In terms of technological access, only 57% of all schools have functional computers, and 53% have internet access. Government schools lag significantly behind private unaided schools in this domain.

Toilet infrastructure remains inconsistent. "67,000 schools still operate without functional toilets... the majority (46,000) are government-run," the Court recorded. Facilities for students with disabilities are also lacking, with "only 33.2% of government schools having disabled-friendly toilets," and only 30.6% of those being functional.

Rajasthan has also seen issues in implementing inclusive education. Over 40,000 private schools were fined for failing to provide facilities for students with disabilities. The lack of physical education programs was also noted, with "half of the schools not offering compulsory physical education."

Gender disparity remains significant. Rajasthan has one of the lowest female literacy rates in the country at 52.66%. Factors such as early marriage, cultural norms, child labor, and safety concerns due to inadequate facilities contribute to low enrollment and retention of girls.

The Court also acknowledged the failure of the Mahatma Gandhi English Medium Schools initiative. Despite converting 3,737 Hindi medium schools into English medium ones, the program faced challenges such as "poor infrastructure, lack of trained English-speaking teachers, and declining student interest."

Prominence was placed on disaster preparedness, particularly in congested urban and rural areas, where many schools remain exposed to hazards. The concept of "School Safety" was broadly defined to include physical, emotional, and transportation-related aspects of student welfare.

Shortage of schools near habitations was another concern. The National Education Policy (NEP) 2020 mandates schools within 1 km of habitation for primary levels and within 3-5 km for secondary levels—a goal far from realized in many districts.

The Court concluded the case background section by stating: "Every child in the State has the right to receive education in a safe school environment. It is the paramount duty of the State to improve educational infrastructures and provide a safe shelter for all school-going children."

Justice Anoop Kumar Dhand discussed the systemic infrastructural deficits and their impact on child safety and education. The Court noted that "Schools are critical institutions, entrusted with the responsibility of shaping the citizens of tomorrow. A safe and secure environment is a prerequisite for effective teaching and learning."

Addressing the need for safe premises, the Court observed: "Prioritizing children’s safety not only safeguards their well-being but also reinforces the role of schools as secure shelters, enabling them to serve a dual purpose as evacuation centers during emergencies."

On inadequate facilities, the Court stated: "In 32% of these schools, there is no electricity connection, forcing children to study under extreme heat conditions." It further recorded that "over 50% of the primary schools are operating without electricity."

Sanitation facilities were critically reviewed: "9% of the Government Schools in State lack functional drinking water facilities on their premises. Approximately 9% of the Government Schools also do not have boys’ toilets, while 10% are without girls’ toilets."

In context of girls’ health, the Court recorded: "Many girls even avoid drinking water during school hours, fearing they will have no access to toilet in school. Medical research has shown that deferring urination can lead to Urinary Tract Infections (UTIs), distended bladders, and various gynecological problems."

Regarding menstrual hygiene, the Court stated: "The absence of separate girls’ toilets coupled with non-availability of free sanitary pads, hampers their academic performance and limits their future opportunities."

On digital learning disparity, the Court noted: "Only 30% of schools in the State have access to computer and out of those, only 24% have functional internet connectivity, severely restricting digital learning opportunities."

The Court further observed that "school infrastructure plays a pivotal role in creating a conducive learning environment and inadequacies in this sphere can severely affect the student’s retention and academic performance."

Nationally, the Court cited UDISE+ data indicating that "1.52 lakh schools still operate without functional electricity... among the 10.17 lakh government-run schools, only 9.12 lakh have access to functional electricity."

Stating neglect in co-curricular development, it noted: "Only 2.57 lakh schools (17.5%) across the country have arts and crafts rooms, with government schools accounting for just 9.9% of this number."

On the issue of science education, the Court recorded: "Among the 2.86 lakh schools that offer secondary education, only 1.6 lakh have integrated science labs. In government secondary schools, only about half (50.2%) ... have this facility."

Sustainable energy adoption was also found lacking. "Only 1.54 lakh schools (10.5%) across India have installed solar panels... in government schools, this figure is even lower—just 89,746 schools (8.8%) have adopted solar energy solutions."

Finally, the Court stated that "addressing these challenges requires dedicated investment in school infrastructure and regular monitoring to promote the importance of education for every child."

In light of its observations, the Court issued show cause notices and proposed several directives. Among them, it directed the authorities: "To conduct a comprehensive survey of every educational institution in the State to ensure that the school premises are safe and not in dilapidated condition that could pose a threat to the lives and safety of students."

"To ensure that all the schools in the State implement adequate measures to ensure the safety of their students."

"To provide appropriate compensation to the parents of the children who have lost their lives as well as to all the students, injured in the school disaster and to ensure access to quality medical treatment and continued education for the affected children in future as well."

"To ensure that both urban and rural areas have sufficient number of government schools for the children proportional to the population of the area."

"To ensure that every school has separate and hygienic toilets for boys and girls."

"To ensure that free sanitary napkins are provided to girls in all the schools."

"To ensure regular supply of electricity along with adequate lighting and fan facilities in all classrooms for the students, the teachers and the staff working in the school premises."

"To establish libraries with all relevant books and computer labs equipped with adequate and reliable internet facilities for the students."

"To develop an online portal and website at every district level, where the students and their parents can submit their grievances including issues related to school infrastructure, with photo evidence and other issues affecting and relating to their studies."

"To create a Redressal Mechanism Forum to look into the grievances of the students/the parents and resolve the same quickly without any delay."

"To fix liability and accountability upon the individuals for poor quality construction of school infrastructure and in the event of any causality or tragedy, in future, to recover the cost of construction from the negligent individuals found liable and responsible."

"To hold a discreet enquiry against all the individuals who are responsible for such incidents and initiate appropriate departmental and criminal actions against them."

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"To constitute district-wise monitoring committees to oversee the infrastructure of all the schools lying in urban and rural areas on monthly basis."

"To promote free sanitary pads to girls by installing sanitary distribution/vending machines near girls’ toilet in the school premises."

"Let a report be summoned from the Chief Secretary of the State of Rajasthan and Secretary of the Ministry of Education and Child Development, New Delhi, about the effective steps taken by the State and the Centre, on the issues involved in this petition."

"Let a copy of this order be sent to all the respondents for their intimation and for submitting compliance report before the Court on or before the next date."

"List on 01.08.2025 at the top of the list before the Bench having roster of Public Interest Litigation."

Case Title: Suo Motu: In the matter of Safety and well-being of school going children
Bench: Justice Anoop Kumar Dhand