Merging a low-enrolment school with a nearby school is not per se arbitrary.

The petitioner challenged the Government notification dated 10 June 2026 merging Government Middle School, Sandyar, Education Block Ghumarwin-I, District Bilaspur, with Government Senior Secondary School, Chhat. It sought quashing of the merger, continuation of the Sandyar school as an independent institution, and preservation of its sanctioned staff, infrastructure and educational facilities.

The State submitted that the merger was undertaken to optimise educational resources and infrastructure, as GSSS Chhat was situated approximately 1.5 km from Sandyar by road and 500 metres on foot.

At the time of merger, only 12 students were enrolled in Classes VI to VIII; 11 were admitted to GSSS Chhat and one to Government High School, Androli. The two teaching and one non-teaching employees of the erstwhile school were also adjusted.

Government Primary School, Sandyar, serving students from Nursery to Class V, continued to function independently with 15 enrolled students.

The petitioner did not dispute the distance between the two schools or assert any present grievance on behalf of the students regarding access to the receiving school.

1. Whether the Government’s decision to merge Government Middle School, Sandyar, with Government Senior Secondary School, Chhat, was arbitrary and liable to be quashed.

2. Whether the merger adversely impaired the students’ access to education so as to warrant judicial interference.

The Court applied the principle that governmental decisions concerning the administration, rationalisation and utilisation of educational institutions and departmental resources are not liable to be interfered with merely because an alternative administrative arrangement may be preferred, unless the decision is shown to be arbitrary or otherwise legally infirm.

It also considered the Himachal Pradesh Right of Children to Free and Compulsory Education Rules, 2025, particularly Part III, Rule 4, which contemplates an upper-primary school being located within a walking distance of 3 kilometres from the neighbourhood and having the requisite availability and willingness for enrolment.

The Court further proceeded on the principle that accessibility of the receiving school and continuity of education are relevant safeguards when assessing the validity of a school merger.

No judicial precedent was cited in the judgment.

The Court found that the merger served a legitimate administrative purpose: the available teaching and non-teaching staff and other educational resources could be better deployed in schools having adequate student strength rather than retained at a school with only 12 middle-school students.

The receiving school was located only 1.5 km away by road and 500 metres on foot, making access reasonably convenient for the affected students.

The students had in fact been accommodated in other schools, and the staff had been adjusted, thereby preserving educational continuity and administrative resources.

Since the petitioner did not dispute the distance or identify any actual difficulty faced by the students, the Court held that the decision could not, on the material before it, be characterised as arbitrary.

The Court observed that interference might have been warranted if the receiving school had been situated at an inaccessible distance, but that circumstance was absent here.

The writ petition was accordingly disposed of without granting the reliefs sought by the petitioner. Pending miscellaneous applications, if any, were also disposed of.