"Institutions Must Remain Spaces Of Safety, Dignity And Intellectual Freedom": Orissa High Court Issues 14-Point Campus Security Directions
Deekshitha Sharmile
The High Court of Orissa, Single Bench of Justice Sanjeeb Kumar Panigrahi, issued a series of directions to ensure safety and security inside and around the campus of National Law University Odisha, Cuttack, which is situated near Naraj, a secluded area on the outskirts of the city. The directions came while the Court was disposing of a petition seeking quashment of criminal proceedings stemming from an alleged incident in which a law student was forcibly detained inside a vehicle, subjected to obscene and sexually offensive remarks, and faced an attempt at abduction near the university campus. The proceedings were ultimately quashed following an amicable settlement between the parties. The Court stressed the duty and responsibility of both the University administration and local police authorities to maintain strict law and order in the vicinity of the institution.
The case originated from a written complaint lodged on 17 September 2023 by a student of National Law University Odisha. The complainant alleged that while returning to the university campus with a friend, three individuals arrived in a vehicle and compelled them to sit inside. It was further alleged that the accused persons questioned them about consumption of alcohol and psychotropic substances, detained the complainant in the car, and directed his friend to call a female acquaintance.
The complaint recorded that the accused persons used obscene language, made sexually offensive remarks, and attempted to abduct the complainant by starting the vehicle with him inside. Based on these allegations, CDA Phase-II Police Station registered Case No. 113 of 2023. The offences invoked included Sections 365, 354-A, 294, 506, and 34-A of the Indian Penal Code.
During pendency of proceedings, the parties submitted that the dispute had been amicably resolved. A joint affidavit was filed affirming settlement, wherein the complainant stated that he no longer wished to pursue the matter, conditional upon assurances of safety from the accused. The affidavit requested quashing of the criminal proceedings on the ground of compromise and mutual consent.
No, it should not. In the judgment, that observation appears in paragraph 12, which comes after the Court has already recorded its reasoning on the continuation of criminal proceedings in paragraphs 8 and 9. Chronologically and logically, the observation on the abuse of process should appear first, followed by the broader campus safety concerns the Court recorded before parting with the case. Here is the corrected version:
On the continuation of criminal proceedings, the Court observed that the de facto complainant had unequivocally expressed his unwillingness to prosecute the matter any further, rendering the likelihood of securing a conviction remote and bleak. It recorded that "in such circumstances, the continuation of the criminal proceeding would not subserve the ends of justice but would instead amount to an abuse of the process of Court."
The Court further stated that "institutions of higher learning must remain spaces of safety, dignity, and intellectual freedom. Any trend of lawlessness, vigilantism, or disorder in and around the campus environment not only jeopardizes students' welfare but also undermines the institutional ethos. It is expected that the concerned authorities, including the University administration and the local law enforcement agencies, shall remain vigilant and take appropriate preventive and remedial measures to ensure that such incidents do not recur, and that the campus atmosphere remains secure and conducive to academic pursuits."
Before parting with the case, the Court stated that "this Court is constrained to observe, with a sense of concern, that there have been recurring and disturbing incidents reported in and around the campus of National Law University Odisha, Cuttack. Such occurrences, particularly involving allegations of intimidation, misconduct, or unlawful interference with students, cast an unwarranted shadow over an institution of national importance entrusted with imparting legal education and upholding constitutional values."
Considering the safety and security of the students as well as their academic interest, the Court issued the following 14-point guidelines:
"The University authorities shall review and, if necessary, augment campus security arrangements, including deployment of adequate security personnel at entry and exit gates, installation and maintenance of functional CCTV cameras at strategic locations, and proper illumination of vulnerable areas."
"The University administration shall maintain regular liaison with the jurisdictional police authorities to ensure prompt response in case of any untoward incident and to conduct periodic patrolling in and around the campus, particularly during late evening hours."
"The Commissioner of Police/DCP concerned shall take necessary steps for establishment of a Police Outpost at Naraj, manned by an officer not below the rank of Sub-Inspector along with adequate supporting staff, so as to ensure effective monitoring of the area adjoining the University campus."
"A Police Beat House shall be established within the campus of National Law University Odisha with provision for 24x7 deployment of police personnel. The University authorities shall extend necessary infrastructural and logistical support for the functioning of the same."
"The jurisdictional police shall take stringent and continuous action to prevent the supply and circulation of alcohol, narcotic drugs, psychotropic substances, and other intoxicants to students, strictly in accordance with the provisions of the applicable penal and special statutes."
"The police authorities shall ensure that no anti-social elements congregate in and around the University campus. The University may regulate student movement during late hours in accordance with its Hostel and Campus Regulations, including requiring prior permission from the Hostel Authorities for movement beyond prescribed hours, subject to reasonable exceptions."
"The University authorities may conduct breathalyzer tests, where there is reasonable suspicion of intoxication, in accordance with law and with due regard to privacy and dignity of students, so as to discourage consumption of alcohol within the campus."
"The University shall strengthen entry-point security by conducting appropriate checks of bags and vehicles entering the campus to prevent entry of contraband materials. Installation of suitable screening or frisking mechanisms at the entrance gate may be undertaken in compliance with legal safeguards and in coordination with the local police administration."
"Periodic inspection of hostel premises may be carried out by the University authorities in accordance with established rules to ensure that students do not keep or consume prohibited substances within the campus."
"In cases where any student is found guilty of consuming or possessing alcohol, tobacco, narcotic drugs, or other prohibited substances in violation of university rules, the parents or guardians of such student shall be duly informed, in addition to initiation of appropriate disciplinary proceedings."
"The University shall explore the feasibility of arranging scheduled bus services between the main city and the University campus during evening hours so as to facilitate safe and regulated transportation of students to the local market and for other necessary outings."
"The University shall conduct periodic awareness programmes sensitizing students regarding personal safety, legal consequences of unlawful acts, and responsible conduct within and outside the campus premises."
"A robust and accessible grievance redressal mechanism shall be maintained, enabling students to report incidents of harassment, intimidation, or misconduct without fear of retaliation. Complaints shall be dealt with promptly and in a time-bound manner."
"The University shall be at liberty to frame or strengthen such additional regulatory and disciplinary measures as may be deemed necessary to preserve campus discipline, safety, and academic decorum, consistent with constitutional and statutory mandates."
Advocates Representing the Parties
For the Petitioners: Mr. Soubhagya Swain, Advocate
For the Respondents: Mr. Sonak Mishra, ASC; Ms. Sarita Moharana, ASC
Case Title: Roshan Kumar Pradhan & Ors. v. State of Odisha & Anr.
Case Number: CRLMC No.391 of 2026
Bench: Justice Sanjeeb K Panigrahi
