Court holds 14 students’ deaths were a tragic accident, not criminal negligence under Section 304A IPC; urges Maharashtra to strengthen beach safety infrastructure
The Bombay High Court has quashed an FIR lodged against trustees, the in-charge principal, teachers and staff of Pune’s Abeda Inamdar Senior College in connection with the 2016 Murud beach tragedy in which 14 third-year B.Sc. students drowned during a college picnic.
In a judgment delivered on October 22, 2026, Justice Milind N. Jadhav held that criminal liability for causing death by negligence under Section 304A of the Indian Penal Code cannot be imposed unless the deaths are shown to be the direct and proximate result of a rash or grossly negligent act of the accused. The court found no such material against any of the applicants.
The case arose from a college picnic held on February 1, 2016, when 116 students and faculty members travelled to Murud beach in Raigad. According to the record, 41 third-year students later revisited the beach and entered the sea. Around 20 to 22 students were caught in strong currents. Though some were rescued with the help of locals, 14 students lost their lives.
An FIR was registered nearly 80 days later at Murud Police Station under Sections 304A and 34 IPC against 17 persons associated with the college, including trustees of the educational trust, the acting principal, assistant professors and support staff. They approached the High Court under Section 482 of the Code of Criminal Procedure seeking quashing of the proceedings.
The High Court ruled that the trustees and office-bearers of the trust could not be prosecuted because they were not present at the picnic spot and there was no material showing any direct or proximate negligent act on their part. The court also held that teachers accompanying first- and second-year students, who had safely returned with the students under their supervision, could not be made criminally liable merely because they belonged to the same institution.
As for the faculty accompanying the third-year students, the court noted that the victims were all major students above 18 years of age and could reasonably understand the consequences of entering the sea at a public beach. Justice Jadhav observed that while some degree of supervision may be expected from accompanying teachers, the law requires proof of gross negligence and a clear causal link between the accused’s conduct and the deaths. In this case, the court said, the immediate cause of death was drowning in seawater, and not any overt negligent act attributable to the applicants.
The judgment drew a distinction between civil negligence and criminal negligence, stressing that a “very high degree” of negligence is necessary to sustain prosecution under Section 304A IPC. Mere lack of ordinary care or the occurrence of an accident, the court said, is insufficient to attract criminal punishment.
The court also discussed the limits of vicarious liability in criminal law, especially in cases involving adult students at public places. It held that criminal prosecution cannot be sustained against trustees, management, or unrelated teachers simply because the picnic was organised by the college.
While granting relief to all the applicants and quashing FIR No. 24 of 2016, the High Court made significant observations on public safety at beaches. It said the State Government also bears responsibility to provide adequate warnings and safety systems at public beaches, including signboards, high-tide alerts, lifeguards, rescue measures, watchtowers, protective barriers, mobile patrols and demarcated safe zones.
Justice Jadhav directed that a copy of the judgment be sent to the Chief Secretary of Maharashtra for considering and fortifying beach safety measures in the larger public interest. The court warned against “knee-jerk reactions” after every tragedy and called for a permanent and uniform beach safety policy across the state.
All four criminal applications were allowed, and the FIR against the applicants was set aside.
Bottom Line:
Penal Code, 1860, Section 304A - Quashing of FIR - College trustees, principal, teachers and staff sought to be prosecuted after 14 major college students drowned during picnic at public beach - In absence of material showing gross or proximate negligent act attributable to applicants, criminal liability under Section 304A cannot be fastened - Vicarious liability cannot be extended to trustees, other teachers or accompanying faculty merely because picnic was organised by college - Court also issued directions/suggestions to State to strengthen beach safety measures.
Statutory provision(s): Indian Penal Code, 1860 Section 304A, Indian Penal Code, 1860 Section 34, Code of Criminal Procedure, 1973 Section 482
P.A. Inamdar v. State of Maharashtra, (Bombay) : Law Finder Doc id # 3000700
