“Institutions Must Remain Spaces Of Safety & Dignity”: Orissa High Court Directs Tightened Security At NLU Odisha Campus
The Orissa High Court on Thursday (February 12) issued a slew of directions for ensuring safety and security inside as well as around the campus of National Law University Odisha, Cuttack (NLUO), which is situated near Naraj, a secluded area at the outskirt of the city.
A Bench of Dr. Justice Sanjeeb Kumar Panigrahi stressed on the duty and responsibility of the University administration as well as the police to maintain strict law and order near the premiere legal institution. The Judge thus remarked –
“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.”
The Court was in seisin over a petition filed under Section 482 of the CrPC seeking to quash an FIR under Sections 365/354-A/294/506/34 of the IPC, pending before the Court of JMFC-I, Cuttack. The FIR is related to a complaint filed by a 4th year student of NLUO on 17.09.2023.
As per his allegations, while he along with his friend was returning from Naraj to the University campus, the petitioners/accused persons approached them in a car and forcefully made them sit inside. Upon reaching the University campus, the petitioners questioned them as to where they had consumed alcohol and psychotropic substances.
The informant further alleged that the petitioners detained him in the car and directed his friend to call his female friend. During the course of the incident, the petitioners allegedly abused them in obscene language and made sexually offensive remarks against their female friends. Thereafter, it is alleged that the petitioners attempted to abduct the complainant by starting the vehicle with him inside.
Basing upon such information, the CDA Phase-II police station registered the FIR and took up investigation. Subsequently, the petitioners filed this petition seeking to quash the criminal proceedings on the basis of mutual settlement between them and the informant. In this respect, they filed a joint affidavit certifying their lack of willingness to pursue the case any further.
The Court took into account the affidavit and it also heard the Registrar, NLUO as well as the Deputy Commissioner of Police (DCP), Cuttack. Though on the request of the parties, the Court agreed to put a quietus to the impending criminal prosecution against the petitioners, it however starkly observed –
“Before parting with the case, 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 so also their academic interest, Justice Panigrahi issued the following 14-point guidelines –
a) 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.
b) 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.
c) 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.
d) 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.
e) 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.
f) 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.
g) 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.
h) 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.
i) 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.
j) 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.
k) 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.
l) 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.
m) 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.
n) 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.
Case Title: Roshan Kumar Pradhan & Ors. v. State of Odisha & Anr.
Case No: CRLMC No. 391 of 2026
Date of Order: February 12, 2026
Counsel for the Petitioners: Mr. Soubhagya Swain, Advocate
Counsel for the Respondents: Mr. Sonak Mishra & Ms. Sarita Moharana, Additional Standing Counsel
Citation: 2026 LiveLaw (Ori) 19