Teacher Has Implied Authority To Enforce Discipline: Kerala High Court Quashes Criminal Case For Caning Students
The case involved charges under Section 324 of the Indian Penal Code and Section 75 of the Juvenile Justice (Care and Protection of Children) Act, 2015.
Justice C. Pratheep Kumar, Kerala High Court
The Kerala High Court set aside the criminal proceedings against a school teacher who had been accused of caning his students.
The case involved charges under Section 324 of the Indian Penal Code (voluntarily causing hurt by dangerous weapons or means) and Section 75 of the Juvenile Justice (Care and Protection of Children) Act, 2015 (punishment for cruelty to a child).
A Bench of Justice C. Pratheep Kumar referred to multiple judicial precedents that examine the permissible limits of corporal punishment by teachers and the circumstances under which such disciplinary action may be justified.
The Court observed, “From the above decisions it is clear that the school teacher, in view of his peculiar position, has authority to enforce discipline and correct a pupil, who is put in his charge. When a parent entrusts a child to a teacher, he on his behalf impliedly consents for the teacher to exercise over the student such authority. When a student does not behave properly or act according to the rules of a school, and if the teacher gives him a corporal punishment for improving his character and conduct, the court has to ascertain whether the said act of the teacher was bona fide or not. If it is found that he had acted with a good intention, only to improve or correct the student, he is within his limits.”
Advocate V.A. Johnson appeared for the Petitioner and Advocate A. Vipin Narayan appeared for the Respondent.
Upon reviewing the First Information Statement (FIS), the High Court noted that the teacher had intervened in a scuffle between students who were striking each other with sticks. In doing so, the teacher had caned only the legs of the students directly involved in the altercation. The Court also pointed out that there was no satisfactory explanation for the four-day delay in reporting the incident and that the student had not received any medical treatment, indicating the absence of serious injury.
After examining the evidence, the Court concluded that the teacher had used only minimal force, intended solely to discipline the students rather than to cause harm. Since there was no proof of bodily injury, the act could not be construed as an offence under the IPC or the JJ Act.
Emphasizing that the teacher’s actions were guided by a corrective purpose and undertaken in good faith, the Court held that his conduct did not constitute cruelty or an unlawful act. Consequently, the High Court allowed the petition and quashed the criminal proceedings initiated against the teacher.
Cause Title: Abhuthahir v. State of Kerala & Anr., [2025:KER:76936]