Bombay High Court Orders Maharashtra Government To Deposit ₹3.60 Crore In Court Over Non-Payment Of Compensation To Victims Of Human Rights Violations
Safiya Malik
The High Court of Bombay, Division Bench of Chief Justice Shree Chandrashekhar and Justice Gautam A. Ankhad last week directed the Maharashtra Government to deposit Rs 3.60 crore with the Court within two weeks, after noting continued non-payment of compensation awarded to victims of human rights violations under recommendations of the Maharashtra State Human Rights Commission. The Bench also ordered the State’s Chief Secretary, in coordination with the relevant departments, to appoint a nodal officer to ensure that notices are served on the victims or their legal heirs and that payments are facilitated. The directions were issued in a public interest petition concerning compliance by State authorities with pending MSHRC compensation recommendations.
A public interest litigation was filed by an individual petitioner against the State Government and other respondents concerning compliance with recommendations of the Maharashtra State Human Rights Commission (MSHRC).
At the hearing, the State’s counsel stated that MSHRC recommendations had been complied with in many cases and sought an adjournment. The State’s counsel was unable to indicate how many recommendations remained uncomplied, and tendered a letter dated 23 January 2026 from the Home Department, submitting that recommendations had been complied with in about 15 cases.
The petitioner contended that MSHRC recommendations have binding force and that the State is under a statutory duty to comply unless the recommendations are challenged in review or appeal, relying on section 18(e) of the Protection of Human Rights Act, 1993.
The Bench recorded the State’s position and request for time, noting that “Stating that in many cases recommendations of the ‘Maharashtra State Human Rights Commission’ (in short, MSHRC) have been complied by the State Authorities, Mr. B. V. Samant, the learned Additional Government Pleader seeks adjournment.”
It also recorded that “the learned Additional Government Pleader is unable to indicate the number of cases/recommendations in which the recommendations of the MSHRC are yet to be complied.” The Court stated that “The learned Additional Government Pleader tenders a copy of the letter dated 23rd January 2026 from the Home Department, Government of Maharashtra and submits that there are about 15 cases in which the recommendations of the MSHRC have been complied by the State Authority.”
On the petitioner’s submissions, the Court recorded that “Mr. Satyam Atul Surana, the petitioner appearing in-person refers to various judicial pronouncements and submits that the recommendations of the MSHRC have binding force in law.” It further recorded the petitioner’s contention that “The State Authority is under statutory duty to comply with the recommendation made by the MSHRC provided the same is not put under challenge in any review or appeal proceeding.” The Court also noted that “The petitioner in-person refers to the provisions under section 18(e) of the Protection of Human Rights Act, 1993 to lay support to his submissions.”
With reference to the State’s response on record, the Bench observed that “Notwithstanding sufficient time granted to the State-respondents, no concrete details are provided by them.”
The Court directed: “In view thereof, we propose to issue a direction to the Principal Secretary, Home Department, Government of Maharashtra to deposit a sum of Rs.3.60 crores with the office of this Court within next two weeks, appropriate arrangements for that shall be made forthwith.”
“However, before that the Chief Secretary in coordination with the Principal Secretary, Home and General Administration Departments, Government of Maharashtra shall appoint a Nodal Officer who shall ensure that notices to all the victims/legal heirs of the victims etc. are served within next 10 days through all available electronic modes in addition to personal service to them.”
“A copy of this order shall also be served upon all such persons in whose favour compensation has been made by the MSHRC. Post the matter on 17th February 2025, High on Board.”
Advocates Representing the Parties
For the Petitioners: Mr. Satyam Atul Surana, Petitioner in-person present.
For the Respondents: Mrs. Neha Bhide, Government Pleader a/w Mr. B. V. Samant, Additional Government Pleader and Mrs. P. J. Gavhane, AGP for Respondents-State; Ms. Krupali H. Rajani & Esha Pachare, Standing Counsel for MSHRC.
Case Title: Satyam Atul Surana Versus The State of Maharashtra & Ors
Case Number: PUBLIC INTEREST LITIGATION NO. 118 OF 2025
Bench: Chief Justice Shree Chandrashekhar, Justice Gautam A. Ankhad
