Human Rights Awards Left Unimplemented: Bombay HC Orders Rs. 3.5 Crore Deposit by State

The Bombay High Court on January 27 directed the Maharashtra government to deposit Rs. 3.5 crore towards compensation recommended in cases of human rights violations that have remained unimplemented for several years, after expressing concern over the State’s prolonged inaction on recommendations issued by the Maharashtra State Human Rights Commission.

A Division Bench comprising Chief Justice Shree Chandrashekhar and Justice Gautam Ankhad was hearing a Public Interest Litigation filed by advocate Satyam Atul Surana, who appeared as a party in person, challenging the non-implementation of recommendations made by the State Human Rights Commission in matters involving human rights violations.

At the outset, the Bench recorded its dissatisfaction with the explanation offered by the State Government regarding the prolonged delay in acting upon the Commission’s recommendations. During the hearing, the Court questioned the State as to why no concrete steps had been taken for nearly a decade to implement compensation awards that had already been recommended in favour of victims after inquiry by a statutory body.

The petition was instituted seeking judicial intervention against what was described as wilful and systematic non-compliance by the State of Maharashtra with recommendations issued under Section 18(e) of the Protection of Human Rights Act, 1993.

The petitioner contended that despite the statutory mandate requiring the State to forward action taken reports on such recommendations, a large number of them had remained pending without any explanation or remedial action.

In support of the petition, reliance was placed on information obtained by the petitioner under the Right to Information Act from the Maharashtra State Human Rights Commission. The data disclosed that between 2013 and 2025, the Commission had issued 180 recommendations in cases involving violations of human rights. Of these, only 44 recommendations had been acted upon by the State Government. The remaining 136 recommendations continued to remain pending without compliance or communication of action taken.

It was placed on record that these pending recommendations involved payment of monetary compensation aggregating to Rs. 3,39,24,000.

The petitioner submitted that the victims in these cases had already undergone inquiry proceedings before the Commission and had been found entitled to relief, but were still awaiting the actual disbursement of compensation owing to the State’s inaction.

The petition further highlighted that the State Human Rights Commission had issued repeated reminders to the concerned departments and authorities seeking compliance and action taken reports in accordance with the statute. Despite such reminders, the recommendations had remained unattended, with no systematic mechanism established by the State to monitor or ensure implementation.

During the course of the hearing, the Bench observed that the explanations offered by the State did not address the prolonged delay spanning several years in implementing recommendations that had not been challenged before any judicial forum.

The Court noted that continued requests for time to compile information could not justify the failure to honour compensation awards meant to remedy established violations of human rights.

Taking note of the magnitude of pending compensation and the absence of effective coordination among departments, the Court directed the Maharashtra government to deposit an amount of Rs. 3.5 crore with the High Court registry.

The Bench clarified that the deposit was intended to secure payment of compensation in cases where awards had remained unimplemented for years and to ensure that victims were not further deprived of relief on account of administrative delays.

In addition to directing the deposit, the Court ordered the appointment of a senior officer of the rank of Principal Secretary as a nodal officer. The nodal officer was tasked with coordinating between multiple departments, securing action taken reports, and ensuring compliance with the recommendations issued by the State Human Rights Commission.

The Court also directed the registry of the High Court to issue notices to victims whose compensation remained pending, along with a copy of the order passed in the proceedings.

The Bench noted that the matter reflected a larger issue of enforcement of recommendations made by statutory human rights bodies and observed that persistent non-compliance undermined the purpose for which such institutions were constituted. It was indicated that recommendations issued after inquiry under the Protection of Human Rights Act could not be treated as optional, particularly when no challenge had been raised to their validity.

The petition remains pending for further monitoring of compliance, and is next listed for hearing on February 17, 2026.

Case Title: Satyam Atul Surana v. State of Maharashtra & Ors.

Bench: Chief Justice Shree Chandrashekhar and Justice Gautam Ankhad

Order date: 27.01.2026