School Management Liable for Investigation into Negligent Supervision and Failure to Safety-Proof Student Transportation Services

The petitioner, a school management, seeks to quash FIR No. 94/2025 registered under Section 125(a) of the Bharatiya Nyaya Sanhita (BNS)

On August 1, 2025, the 4th-standard son of Respondent No. 2 was traveling in the school bus when other children allegedly sprayed colored confetti/sparklers, causing a severe eye injury

Medical assessments confirmed the child suffered permanent disability of 40% to the whole body

The complainant alleged gross negligence by the management for failing to provide an attendant, failing to ensure the CCTV was functional, and failing to supervise the students

The management contended it is not liable for the acts of children occurring after school hours

1. Whether the school management can be held prima facie liable under Section 125(a) of the BNS for negligence occurring within a school bus

2. Whether the investigation against the school management should be quashed on the grounds that the incident was an act of another child beyond school hours

Section 125(a) of the Bharatiya Nyaya Sanhita (BNS), 2023, which penalizes rash or negligent acts endangering human life or personal safety resulting in hurt

Section 1C of the Karnataka Educational Institutions (Classification, Regulation and Prescription of Curricula, etc.,) (Amendment) Rules, 2018, which mandates that school managements provide attendants in buses, ensure teachers/attendants accompany students to the last stop, and supervise vehicle movements for student safety

The Court reasoned that a school’s duty of care is an "extension of the school itself" and does not end at the classroom door; it continues until the child is restored to the parent

By failing to ensure a functional CCTV and the presence of a mandatory attendant—as required by the 2018 Rules—the management prima facie breached a statutory "solemn obligation"

The Court rejected the petitioner’s argument that the act was solely attributable to another child, noting that the lack of supervision and the entry of dangerous materials (sparklers) into the bus are matters requiring investigation

Since the ingredients of Section 125(a) regarding negligence were met in the complaint, quashing the FIR at the threshold would prematurely foreclose criminal accountability for a lifelong injury

It held that the safety of children in school transport is a mandatory statutory duty and any lapse therein warrants a full investigation

The interim stay on the investigation was vacated, and the Court ordered that the investigation must proceed to determine the precise contours of the management's culpability