Kerala High Court quashes teacher’s prosecution, finding no criminal intent in a classroom discipline incident that caused a student minor injury

The petitioner, a teacher and class teacher of Standard V-C at MGM School, Thiruvalla, was accused of catching hold of a student’s hand and pulling her while attempting to maintain classroom discipline.

The student’s leg allegedly became entangled in a bench, causing pain and a contusion to her right knee.

The police initially registered the crime under Sections 75 of the Juvenile Justice (Care and Protection of Children) Act, 2015 (“JJ Act”) and 323 of the IPC, but filed a final report alleging offences under Section 82(1) of the JJ Act and Section 323 of the IPC.

The petitioner sought to quash the final report and proceedings in S.C. No. 657/2024, contending that the incident involved only a disciplinary measure and that the materials did not establish the offences.

Whether the allegations and investigation materials disclosed the ingredients of an offence under Section 82(1) of the JJ Act or Section 323 of the IPC.

Whether the High Court should exercise its inherent power under Section 528 of the BNSS to quash the final report and pending proceedings.

Section 82(1) of the JJ Act addresses corporal punishment, and Section 323 of the IPC concerns voluntarily causing hurt.

The Court stated that a teacher’s trivial punishment, imposed as a corrective measure or to maintain discipline, does not by itself warrant criminal prosecution; however, corporal punishment inflicted with mala fide intent and potentially serious consequences for a child must be dealt with seriously.

Under Section 528 of the BNSS, the High Court may exercise its inherent power to prevent abuse of the process of court and secure the ends of justice.

The Court considered the witness statements, which indicated that the petitioner caught and pulled the student’s hands as a measure to maintain classroom discipline, without an apparent mala fide intention to harass, abuse, or injure her.

The wound certificate recorded only minor injuries, and the investigation materials did not establish the requisite criminal conduct for either alleged offence.

In those circumstances, the Court found that continuing the prosecution would amount to an abuse of process and justified invoking Section 528 of the BNSS.

It allowed the petition and quashed the final report in Crime No. 158/2019 and all further proceedings in S.C. No. 657/2024 before the Additional Sessions Court-I, Pathanamthitta.