High Court Observes Inaction of College Authorities Led to Tragic Incident
In a high-profile case from Balasore, Odisha, the Orissa High Court on October 22, 2025, rejected the bail pleas of the Head of Department (HOD) and Principal of Fakir Mohan Autonomous College (FMAC), accused in the self-immolation of a female undergraduate student.
The Bench of Justice Aditya Kumar Mohapatra noted the gravity of the incident and observed:
“This Court painstakingly notes that all preventive steps have failed and society collectively failed to save the life of a young girl. The inaction of the college authorities would be the sole reason for the deceased taking such an extreme step.”
Case Background
On July 12, 2025, a female student of FMAC set herself ablaze on campus following alleged repeated sexual and mental harassment by the HOD. Despite immediate medical attention, she succumbed to fatal burn injuries on July 14, 2025.
Prior to the incident, the student had reported harassment to the Principal, but her grievance was allegedly ignored. Student protests prompted the constitution of an Internal Complaints Committee (ICC) under the Sexual Harassment of Women at Workplace Act, 2013, which reportedly found no merit in her complaint. Dissatisfied with the findings, the student tragically immolated herself.
The police arrested the HOD and Principal immediately after the incident. Subsequently, two students were also taken into custody for their alleged role in abetting the act. Bail pleas before the SDJM and Sessions Court, Balasore, were rejected, prompting the accused to approach the Orissa High Court.
Grounds for Bail Pleas
HOD Samira Kumar Sahoo contended that the student’s self-immolation resulted from political disputes, alleging he was falsely implicated without any incriminating evidence.
Principal Dillip Kumar Ghose, represented by Senior Advocate Debi Prasad Dhal, argued that:
- An ICC had been constituted and a report submitted on July 9, 2025.
- The deceased acted after learning about the ICC findings.
- Arrest procedures allegedly bypassed Sections 47 and 48 of BNSS 2023 and Article 22(1) of the Constitution.
Student accused Subhra Sambit Nayak was implicated due to telephonic conversations with the deceased. Counsel argued the student had a cordial relationship with her and actively participated in protests, urging bail due to age and future prospects.
Student accused Jyotiprakash Biswal was alleged to have recorded the incident, but the FIR did not implicate him, and he reportedly attempted to save the victim, suffering burn injuries. Counsel requested bail considering lack of evidence and career prospects.
Court’s Observations on Bail
Justice Mohapatra highlighted the inaction of college authorities as the primary factor leading to the tragedy, stating:
“It is not very difficult to understand the genesis of the thought-process which led to such a drastic step by a young girl student; it is entirely due to the hierarchy of the college administration and their inaction towards the harassment complained of by the victim.”
The Court noted that the investigation by the Crime Branch is ongoing and the final charge-sheet is yet to be filed, making bail for the HOD and Principal premature.
Regarding alleged statutory non-compliance under Sections 47 and 48 BNSS 2023, the Court reviewed the arrest memo, observing:
“The memo clearly indicates prima facie evidence under Sections 75(1)(ii), 78(2), 79, 351(2), 108, 3(5) of BNSS, 2023. The accused were informed of the grounds of arrest, complying with statutory provisions.”
Thus, bail pleas of the HOD and Principal were rejected.
Conversely, considering the absence of allegations against the student accused in the FIR and witness statements, the Court allowed bail for Subhra Sambit Nayak and Jyotiprakash Biswal, with liberty for prosecution to seek cancellation if incriminating material emerges.
Case Details
- Case Title: Samira Kumar Sahoo v. State of Odisha & tagged matters
- Case Nos.: BLAPL Nos. 9219, 9241, 9242 & 9739 of 2025
- Date of Order: October 22, 2025
- Court: Orissa High Court
- Bench: Justice Aditya Kumar Mohapatra
- Counsel for Petitioners:
- Mr. Bijaya Kumar Behera, Advocate for Samira Kumar Sahoo
- Mr. P.K. Parhi & Mr. P.K. Mishra for Jyotiprakash Biswal
- Mr. P.K. Parhi, Mr. B. Parhi & Mr. S. Suman for Subhra Sambit Nayak
- Senior Advocate Debi Prasad Dhal & Mr. A. Ray for Dillip Kumar Ghose
- Counsel for State: Mr. Partha Sarathi Nayak, Additional Government Advocate
