Can Courts Order Public Shaming? Allahabad High Court Quashes Order Forcing Student to Carry ‘Will Not Misbehave' Placard

The Allahabad High Court recently set aside a condition imposed on a university student requiring him to publicly display a placard stating that he would never misbehave with any girl, holding that such a direction was "humiliating" and capable of leaving a permanent scar on the student’s character.

A division bench comprising Chief Justice Arun Bhansali and Justice Kshitij Shailendra was dealing with a special appeal filed by a student of Galgotias University challenging an order passed by a single judge on October 29, 2025, in a writ petition arising out of the student’s rustication by the university.

The single judge had earlier set aside the order of rustication but, while exercising powers under Article 226 of the Constitution, imposed several conditions on the student. These conditions included a requirement that the student file a notarised affidavit undertaking to attend at least 95 per cent of the remaining classes, not leave the university premises during class hours, and submit leave applications in case of absence. The student was also directed to tender a written apology to the university within 72 hours.

In addition, the single judge directed the police authorities to deploy an anti-romeo mobile squad at the time of opening and closing of the university gates. Non-compliance with these directions was made a ground for permitting the university to rusticate the student again without issuing any further notice.

However, one particular condition formed the core of the challenge before the division bench. Under this direction, the student was required to stand at the main gate of the university every morning from 8:45 am to 9:15 am for 30 days, holding a placard with a message stating that he would never misbehave with any girl. The university was also directed to photograph this act, and failure to comply was made a ground for fresh rustication.

However, one particular condition formed the core of the challenge before the division bench. Under this direction, the student was required to stand at the main gate of the university every morning from 8:45 am to 9:15 am for 30 days, holding a placard with a message stating that he would never misbehave with any girl. The university was also directed to photograph this act, and failure to comply was made a ground for fresh rustication.

Appearing for the appellant, counsel argued that the placard-related condition was not only degrading but would also have long-term consequences for the student’s future and career. It was submitted that such a direction amounted to public shaming and went far beyond the scope of reasonable disciplinary or corrective measures.

On the other hand, counsel for the university supported the single judge’s order, contending that the writ petition itself was not maintainable and that the directions were issued after taking a humanitarian view of the student’s background. The single judge had noted that the student’s father was a poor farmer and that the student was pursuing his education with great difficulty.

After condoning a delay of 57 days in filing the appeal, the division bench examined the nature of the directions imposed. While the court found that the conditions relating to attendance, filing of an apology, and police deployment were justified in view of the student’s conduct and his earlier attendance record of around 50 per cent, it strongly disapproved of the placard requirement.

The bench observed that directing a student to stand at the university gate with a placard declaring that he would never misbehave with any girl was “not justified under any circumstances.”

Court held that such a measure was inherently humiliating and would cast a permanent stigma on the character of the student, which was not warranted in the facts of the case.

Accordingly, the division bench set aside the impugned direction relating to the placard. It further clarified that if the student had been rusticated again solely due to non-compliance with this condition, he would be given one opportunity to comply with the requirement of filing a written apology. Upon such compliance, the rustication would stand set aside, subject to the student strictly adhering to the attendance-related conditions imposed earlier.

With these observations, the appeal was disposed of on February 4, 2026.

Case Title: ABC vs. Chairman U.G.C. Bahadurshah Zafar Road And 5 Others

Order Date: February 4, 2026 

Bench: Chief Justice Arun Bhansali and Justice Kshitij Shailendra