The Madhya Pradesh High Court has directed the Gram Panchayat of Umaria to take proactive measures, including passing a resolution, to mitigate and remove the infrastructure deficiencies in the only school operating within the said area. [2026 LiveLaw (MP) 241]

The division bench of Acting Chief Justice Vivek Rusia and Justice Pradeep Mittal was dealing with a public interest litigation seeking cancellation of recognition of a private school, on the grounds that it lacked basic amenities, including seating arrangements, toilets, drinking water facilities, blackboards, safety measures, and electricity.

The bench refused to cancel the private school's recognition, noting that:

"Since this is the only school operational within the Gram Panchayat and there is no alternative Government school available, closing down the institution would directly jeopardise the academic future of the local children. Therefore, instead of shutting down or withdrawing the recognition of the private school, constructive and coordinated efforts must be made by all stakeholders to systematically eliminate the highlighted deficiencies in the public interest. There should be a constructive approach while dealing with PIL by the High Court".

Therefore, the bench directed:

"The petitioners, being the Sarpanch and Up-Sarpanch of Gram Panchayat Kotari, Janpad Panchayat Manpur, owe a public duty to facilitate education and ensure better civic amenities for the villagers and their children. Let the Gram Panchayat take up this matter in its General Body Meeting and pass a resolution delineating how these deficiencies can be mitigated and removed with the active assistance and cooperation of the local villagers".

The petition was filed by the members of the Gram Panchayat claiming to be social activists against Devarsi High School, a private school run by respondents no 8 in Village Kotari, District Umaria.

The petitioners contended that they had raised their grievances before the competent authority, which led to an inquiry being conducted by the Block Education Officer. The petitioners further claimed that the inquiry report showed the condition of the school building to be unsatisfactory and unsafe. Accordingly, a recommendation was forwarded to the District Education Officer to take appropriate action.

The petitioners also referred to a spot inspection report, which recorded the lack of toilet facilities in the school, compelling students to relieve themselves in the open. Additionally, the petitioners claimed that a notice was issued to the principal of the school seeking an explanation of the deficiencies, and no explanation was filed by the principal.

The petitioners also informed the court regarding another PIL filed by then in2025, which was dismissed with liberty to pursue pending representation before the competent authorities.

The court noted that there was no other government school that was operating in the area, and the said private school was the only school available. Further, the bench empasizing the "academic future' of the local children, refused to shut down the school. Thus, by passing the aforementioned directions, the court disposed of the petition.

Case Title: Manggi Bai Kole v State of Madhya Pradesh, WP-43662-2025

Citation: 2026 LiveLaw (MP) 241

For Petitioner: Advocates Munendra Singh and Vineeta Soni

For State: Deputy Advocate General Vivek Sharma

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