In a significant move aimed at safeguarding the student community, the Orissa High Court has issued a series of mandatory safety and security guidelines for educational institutions, particularly focusing on the National Law University Odisha (NLUO). Stressing that higher learning centers must be "spaces of safety and dignity," the Court underscored the shared responsibility of university administrations and local police in preventing lawlessness around campus environments.

The judgment, delivered by Justice Sanjeeb Kumar Panigrahi, comes in the wake of a harrowing incident involving the alleged abduction and harassment of a law student. While the Court allowed the quashing of the specific criminal case based on a mutual settlement, it refused to ignore the larger systemic security lapses that the incident brought to light.

The case (Roshan Kumar Pradhan & Ors. v. State of Odisha) originated from an FIR filed by a 4th-year student of NLU Odisha in September 2023. According to the complaint, the student and a friend were returning to the campus from the Naraj area—a somewhat secluded outskirts zone of Cuttack—when they were intercepted by individuals in a car.

The accused allegedly forced the students into the vehicle, subjected them to verbal abuse and obscene language, and made sexually offensive remarks. Most alarmingly, the petitioners reportedly attempted to abduct the complainant by driving away while he was still trapped inside the car.

Although the parties eventually reached a settlement and moved the High Court to quash the FIR, the Bench noted with "grave concern" that such incidents cast a shadow over institutions of national importance.

Justice Panigrahi’s observations in the judgment serve as a stern reminder to authorities. He 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."

The Court noted that NLUO is situated in a relatively isolated area, making students vulnerable to anti-social elements, especially during late hours.

To ensure that such "recurring and disturbing" incidents do not happen again, the Orissa High Court issued a detailed 14-point guideline. These directions are expected to serve as a benchmark for other universities across the state.

1. Enhanced Surveillance and Lighting

The University has been directed to review and augment its security personnel at all entry and exit points. Furthermore, the Court made it mandatory to install and maintain functional CCTV cameras at strategic locations and ensure "proper illumination" of vulnerable or dark stretches in and around the campus.

2. Dedicated Police Presence

Recognizing the isolation of the Naraj area, the Court directed the Commissioner of Police and the DCP of Cuttack to:

Establish a Police Outpost at Naraj, headed by an officer not below the rank of Sub-Inspector.
Set up a Police Beat House inside the NLUO campus with 24/7 deployment of personnel.

3. Crackdown on Narcotics and Alcohol

One of the most stringent parts of the guideline involves the supply of intoxicants. The Court ordered the jurisdictional police to take "stringent and continuous action" to prevent the circulation of alcohol, narcotic drugs, and psychotropic substances among students.

4. Regulated Movement and Breathalyzer Tests

While upholding the dignity of students, the Court allowed the University to:

Regulate student movement during late hours.
Conduct breathalyzer tests based on "reasonable suspicion" of intoxication, provided it is done with due regard to privacy.
Perform periodic inspections of hostel premises to ensure no prohibited substances are stored or consumed.

5. Transportation and Safe Commute

To bridge the gap between the secluded campus and the main city, the Court suggested that the University explore providing scheduled bus services during evening hours. This move is aimed at preventing students from having to rely on unsafe private transport or walking through deserted stretches to reach local markets.

6. Grievance Redressal and Awareness

The judgment emphasizes a "robust and accessible" grievance mechanism where students can report harassment or misconduct without fear of retaliation. Additionally, the Court called for periodic awareness programs to sensitize students about personal safety and the legal consequences of unlawful acts.

Throughout the guidelines, the Court maintained a delicate balance between campus discipline and student rights. For instance, while allowing bag checks and frisking at entry points, Justice Panigrahi specified that these must be done in compliance with "legal safeguards" and in coordination with local police.

In cases where a student is found violating university rules regarding alcohol or drugs, the Court directed that parents or guardians must be duly informed, alongside the initiation of disciplinary proceedings.

This judgment is a landmark because it moves beyond the specific facts of a criminal case to address the environmental safety of students. By involving the highest levels of district police (DCP and Commissioner), the Court has ensured that campus security is no longer viewed as just an "internal matter" of a university, but a critical aspect of public law and order.

For students at NLU Odisha and similar institutions, the ruling promises a more secure environment where academic pursuits are not hindered by the fear of external threats. For the administration, it is a clear directive: the safety of the student is paramount, and negligence will no longer be overlooked.

The Orissa High Court’s intervention serves as a wake-up call for educational institutions nationwide. As Justice Panigrahi concluded, the campus atmosphere must remain "secure and conducive to academic pursuits." The implementation of these 14 points will be closely watched, as they represent a major step forward in protecting the "dignity and welfare" of the next generation of legal professionals.

Case Details:

Case Title: Roshan Kumar Pradhan & Ors. v. State of Odisha & Anr.
Case No: CRLMC No. 391 of 2026
Bench: Dr. Justice Sanjeeb Kumar Panigrahi
Date of Order: February 12, 2026