“Bihar Police's Circular On Girls' Safety In Hostels Lacks Penal Consequences For Non-Compliance; Must Be Enforced”: Patna High Court

The Patna High Court has observed that the circular issued by the Bihar Police regarding safety measures for girls residing in private hostels and lodges does not provide for any penal consequences in case of non-compliance, and emphasised that the same must be strictly implemented with follow-up action.

A Division Bench comprising Chief Justice Sangam Kumar Sahoo and Justice Harish Kumar was hearing a Public Interest Litigation concerning necessary consultation and guidelines for ensuring safety of female students residing in girls' hostels and lodges in the State of Bihar.

The matter relates to a Circular dated 04.02.2026 issued by the Bihar Police Headquarters through the Additional Director General of Police (Weaker Section), with the approval of the Director General of Police, which was placed before the Court pursuant to an earlier order dated 10.04.2026. The Circular noted that in recent times certain criminal incidents had occurred involving girls and women residing in hostels and lodges for the purpose of education, and emphasised that it is imperative for the State, particularly the police, to take preventive measures to provide a safe environment for them.

The Circular issued advisory directions regarding operation of girls' hostels and lodges, including mandatory registration and verification of such establishments, police verification of staff, installation of security infrastructure such as CCTV cameras, ensuring proper lighting, hygiene and sanitation, regulating entry and exit, including restrictions on entry of men in specified areas, and maintenance of biometric attendance for students and staff.

Upon perusal of the Circular, the High Court noted that although detailed directions had been issued, there was no indication as to what action would be taken if the management of such hostels or lodges failed to comply with the requirements, including registration and other safety measures. The Counsel for the State accepted that this aspect had not been addressed and that necessary amendment would be required in that regard.

The Court further queried the State as to whether it had obtained instructions regarding the number of such private girls' hostels and lodges operating in Bihar, the districts in which they are situated, and the police jurisdictions under which they fall. The learned Senior Counsel for the State sought time to obtain the necessary instructions.

Emphasising the need for effective implementation, the Court observed that the Circular itself requires that action taken in light of the instructions, along with reports, be sent by the 15th of every month, and directed that on the next date the State must apprise the Court as to how many such reports have been received from Superintendents of Police and other concerned district officials.

The Court further observed that the issue involved in the PIL is a sensitive one aimed at creating a safe environment for girls and women residing in private hostels and lodges for education or livelihood, and therefore the Circular must be strictly implemented and followed by necessary action. It indicated that in cases of violation, action in accordance with law, including imposition of fine or penalty and, if necessary, closure of such hostels or lodges, should be taken against the management.

The matter has been directed to be listed on 11.05.2026 for further consideration.

Case Title: Madhav Raj (In Person) v. State of Bihar and Ors.

Case No.: Civil Writ Jurisdiction Case No. 1142 of 2026.

Appearance: Mr. Madhav Raj appeared in person for the petitioner, Mr. P.K. Verma and Mr. Sanjay Kumar Ghosarvey appeared for the State.

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