In a significant ruling emphasising dignity and proportionality in disciplinary measures, the Allahabad High Court recently set aside a controversial condition that required a university student to stand at the campus gate with a placard promising not to misbehave with girls. The decision in Harsh Awana v. Chairman U.G.C. Bahadurshah Zafar Road & Ors. highlights the judiciary’s growing reluctance to endorse punishments that amount to public shaming.
A Division Bench comprising Chief Justice Arun Bhansali and Justice Kshitij Shailendra held that compelling a student to publicly display such a message was “humiliating” and could leave a lasting stigma on his character. While the Court upheld several other disciplinary directions, it made it clear that the placard requirement crossed the line of permissible corrective action.
Background of the Case
The matter arose from a challenge to a university’s decision to rusticate a student following allegations of misconduct. The student had approached the High Court earlier, seeking relief against the disciplinary action imposed by the institution.
In an order dated October 29, 2025, a single-judge bench had set aside the rustication after considering the student’s socio-economic background, noting that his father was a poor farmer who had struggled to support his education. However, while granting relief, the single-judge imposed several conditions aimed at reforming the student’s behaviour.
Among these were maintaining 95 percent attendance in remaining classes, submitting written leave applications for absences, remaining within university premises during class hours, filing a written apology within 72 hours, and a particularly contentious direction — requiring him to stand at the university gate for 30 minutes each day for a month holding a placard stating that he would never misbehave with girls.
The order also directed deployment of an anti-romeo mobile police squad at the campus gates during opening and closing hours and warned that the student could face fresh rustication without notice if further complaints arose.
Appeal Before the Division Bench
Challenging the order, the student argued that the placard requirement amounted to public humiliation and could severely damage his reputation and future prospects. He contended that such a punishment was disproportionate and violated principles of dignity and fairness.
The university defended the earlier order, submitting that the original petition should not have been entertained and that the conditions imposed were corrective rather than punitive. According to the institution, the measures were intended to ensure discipline and prevent further misconduct on campus.
The Division Bench was therefore called upon to balance the need for maintaining discipline in educational institutions with the fundamental rights of the student.
Court’s Observations
While examining the issue, the High Court acknowledged that educational institutions have the authority to impose reasonable conditions to maintain order and ensure a safe environment for students. However, the Bench drew a clear distinction between corrective measures and punishments that degrade an individual’s dignity.
The Court observed that directing a student to carry a placard with a self-incriminating message and stand publicly at the campus gate was not only humiliating but also likely to leave a permanent mark on his character. Such a direction, it held, was not justified in the circumstances of the case.
Importantly, the Bench clarified that while disciplinary action may be necessary, it must remain proportionate and consistent with constitutional values, including the right to dignity under Article 21.
Conditions Upheld by the Court
Despite striking down the placard requirement, the High Court upheld several other conditions imposed by the single-judge. These included:
- Maintaining high attendance in remaining classes.
- Submitting a written apology to the university authorities.
- Adhering to campus rules and restrictions during class hours.
- Police deployment at university gates as a precautionary measure.
The Court found these measures to be reasonable and aligned with the objective of maintaining discipline, especially considering the student’s previous attendance record and the nature of allegations against him.
Directions Issued by the High Court
In its final directions issued on February 4, the Division Bench set aside only the placard condition while keeping the remaining directions intact. The Court also clarified that if the student had been rusticated again solely because he refused to comply with the placard requirement, he must be given a fresh opportunity to submit the written apology.
Upon fulfilling the other conditions laid down by the Court, the rustication would stand cancelled, and the student would be allowed to continue his education subject to compliance with attendance rules.
Legal Significance of the Ruling
The judgment reflects a broader judicial trend against public shaming as a form of punishment. Courts across India have increasingly emphasised that disciplinary or corrective measures must respect individual dignity and avoid stigmatization.
By striking down the placard direction, the Allahabad High Court has sent a strong message that even well-intentioned judicial orders must remain within constitutional boundaries. The ruling underscores that reformative justice cannot come at the cost of humiliation.
The decision also highlights the delicate balance courts must maintain when dealing with student discipline cases — ensuring campus safety while safeguarding the rights and future prospects of young individuals.
Representation
The student was represented by advocate Gopal Srivastava. The respondents were represented by Senior Counsel Jagdish Pathak along with advocates Anubhav Singh and Pratik Chandra.
Conclusion
The Allahabad High Court’s ruling in Harsh Awana v. Chairman U.G.C. serves as a reminder that justice must not only be corrective but also humane. By setting aside the controversial placard punishment, the Court reaffirmed that public humiliation has no place in disciplinary jurisprudence.
At the same time, by upholding other reasonable conditions, the Bench struck a balance between institutional discipline and constitutional safeguards. The decision is likely to influence future cases involving student misconduct, reinforcing that dignity remains a non-negotiable principle even in corrective measures.
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