“Campus Must Remain a Safe Space”: Orissa HC Orders Police Outpost, 24×7 Beat House for NLU Odisha

The Orissa High Court has quashed criminal proceedings arising out of an alleged abduction and harassment incident involving students of National Law University, Odisha, holding that the continuation of the case would amount to an abuse of the process of court in view of a voluntary settlement between the parties and the bleak possibility of conviction.

While granting relief to the accused in exercise of its inherent powers, the Court simultaneously expressed deep concern over recurring incidents in and around the NLU Odisha campus and issued an extensive set of directions to the university administration and the local police to ensure a safe, disciplined and academically conducive environment for students.

The matter was heard by Dr. Justice Sanjeeb Kumar Panigrahi, who allowed the petition under Section 482 of the CrPC and quashed the criminal proceedings pending before the court of the JMFC-I, Cuttack.

Relying on the principles laid down by the Supreme Court in Gian Singh v. State of Punjab as well as earlier decisions of the High Court, the Bench held that since the de facto complainant had unequivocally stated through a joint affidavit that the dispute had been amicably settled and that he did not wish to pursue the prosecution, the likelihood of securing a conviction had become remote and the continuation of the trial would not serve the ends of justice.

The case originated from a complaint lodged by a fourth-year student of NLU Odisha, who alleged that while he and a friend were returning to the university campus from Naraj Dam, they were forcibly made to sit inside a vehicle by three persons.

It was alleged that near the campus gate the accused questioned them about the consumption of alcohol and psychotropic substances, abused them in obscene language and made sexually coloured remarks about their female friends.

The complainant further alleged that an attempt was made to drive away with him inside the vehicle. On the basis of these allegations, offences under Sections 365, 354-A, 294 and 506 of the IPC were invoked and the case was registered at CDA Phase-II Police Station, Cuttack.

During the pendency of the proceedings, however, the accused and the complainant filed a joint affidavit stating that the matter had been settled with the intervention of well-wishers and that the complainant no longer wished to continue with the case.

The affidavit recorded that the settlement was voluntary and based on an assurance that no harm would be caused to the complainant in the future.

Taking note of this position, the Court observed that the inherent jurisdiction of the High Court is meant to prevent abuse of process and to secure the ends of justice, and that in cases of a personal nature where the victim is unwilling to support the prosecution, the continuation of criminal proceedings would be an exercise in futility.

Even as it quashed the case, the Court made significant and wide-ranging observations about the larger situation prevailing in and around the NLU Odisha campus. It noted with concern that repeated incidents involving intimidation, misconduct and unlawful interference with students cast an unwarranted shadow over an institution of national importance entrusted with imparting legal education and upholding constitutional values.

Emphasising that institutions of higher learning must remain spaces of safety, dignity and intellectual freedom, the Court said that any trend of lawlessness or vigilantism in the campus vicinity not only jeopardises student welfare but also undermines the institutional ethos.

In this backdrop, the Court issued a series of mandatory directions aimed at creating a long-term preventive and monitoring framework. It directed the university authorities to review and augment security arrangements, including deployment of adequate personnel, installation and maintenance of functional CCTV cameras at strategic locations and proper illumination of vulnerable areas.

It ordered regular liaison between the university administration and the jurisdictional police for prompt response to untoward incidents and for periodic patrolling, particularly during late evening hours.

The Commissioner of Police and the DCP concerned were directed to take steps for the establishment of a police outpost at Naraj and for setting up a police beat house inside the campus with round-the-clock deployment of personnel, for which the university would provide necessary logistical support.

The Court further directed the police to take stringent and continuous action to prevent the supply and circulation of alcohol, narcotic drugs and psychotropic substances to students and to ensure that anti-social elements do not congregate in and around the campus.

The university was permitted to regulate late-hour movement of students in accordance with hostel and campus regulations, conduct breathalyser tests in cases of reasonable suspicion while respecting privacy and dignity, strengthen entry-point checks to prevent contraband and carry out periodic inspections of hostel premises in accordance with established rules.

It also directed that parents or guardians be informed where students are found in possession of or consuming prohibited substances, that the feasibility of scheduled bus services between the city and the campus be explored for safer student movement, and that periodic awareness programmes on personal safety, responsible conduct and the legal consequences of unlawful acts be organised.

The Court emphasised the need for a robust and accessible grievance redressal mechanism enabling students to report incidents without fear of retaliation and clarified that the university would be at liberty to frame additional regulatory measures consistent with constitutional and statutory mandates to preserve campus discipline and safety.

The order thus goes beyond the quashing of a criminal case to address systemic concerns relating to the security and governance of a premier legal education institution, underscoring the joint responsibility of the university administration and the law enforcement machinery in ensuring a secure and conducive academic atmosphere for students.

Case Title: Roshan Kumar Pradhan & Ors. v. State of Odisha & Anr.

Bench: Dr. Justice Sanjeeb Kumar Panigrahi

Date of Order: February 12, 2026