‘Revengeful, Vulgar, Rebellious’: Madhya Pradesh HC Upholds Expulsion of Student for Social Media Posts on Teachers

The bench of Justice Pranay Verma held that the Madhya Pradesh State Commission for Protection of Child Rights’ order directing the school to reinstate the student was merely advisory and not legally binding. “The Commission has no power to adjudicate any lis between two parties,” the court said, referring to the judgments from Karnataka, Kerala, and Madras High Courts that define such commissions as recommendatory bodies.

The petitioner’s son, then a Class 9 student, had, along with two classmates, created an Instagram page using the school’s name, posting memes and captions that mocked several teachers. Some of the posts reportedly used abusive language, depicted teachers in derogatory caricatures, and even made communal references. After being confronted, the students admitted their misconduct and tendered written apologies.

Despite the apology, the school suspended the student for the rest of the academic year, allowing him only to take the final examination, and later informed his father that he would not be readmitted to Class 10. The father approached the State Commission for Protection of Child Rights, which ordered the school on April 3, 2025, to revoke the termination and provide counseling. However, the school refused to comply, arguing that such directives had no binding legal effect.

Before the court, the petitioner argued that the school’s action violated his son’s right to education under Article 21-A of the Constitution, the Right to Education Act, 2009, and the Juvenile Justice (Care and Protection of Children) Act, 2015.

The school countered that it had acted within its rights as a private unaided institution to uphold discipline and moral order on campus. It also emphasized that the Commission’s orders did not override the school’s administrative autonomy.

Court examined the material submitted by the school in a sealed cover, which included screenshots of Instagram posts and chat logs, and found that the content was “highly abusive, vulgar, and communal in tone,” displaying a “revengeful and rebellious attitude".

It rejected the petitioner’s plea that the boy was too immature to grasp the consequences of his actions, holding that the student’s conduct reflected “sufficient mental development to understand the gravity of his acts".

Justice Verma observed that the principal of a school is the guardian of its discipline and morality and that courts should exercise restraint in reviewing decisions concerning student indiscipline.

“The power of judicial review in such cases is very limited. This court cannot sit in appeal over the school’s disciplinary decision,” the order stated.

While upholding the school’s decision, court took note of the revised Transfer Certificate issued to the student, which described him as having a “good character". This, the judge said, eliminated any impediment to his future admission elsewhere.

Finding no illegality or arbitrariness in the school’s decision, the High Court dismissed the petition.

Case Title: X vs State of Madhya Pradesh and Others

Order Date: October 9, 2025

Bench: Justice Pranay Verma