Fourteen students died in the sea at Murud in February 2016, and the Bombay High Court Quashes FIR against the Pune college’s in-charge principal, trustees and teachers, holding that adult students swept away at a public beach was a simple accident and that beach safety is the State’s responsibility.
Mumbai: First Information Report No. 24 of 2016, registered at Murud Police Station in Raigad against the trustees, the in-charge principal, teachers and staff of a Pune college over the deaths of 14 students who drowned during a college picnic at Murud beach, has been quashed by the Bombay High Court. They cannot be held criminally negligent for an unforeseeable event, the Court held, and safety on public beaches rests with the State [P.A. Inamdar and Others v. State of Maharashtra and Another].
Four applications under Section 482 of the Code of Criminal Procedure, 1973, filed by the 17 persons named in the FIR, were allowed by Justice Milind N. Jadhav in a judgment delivered on October 22, 2026. The FIR invoked Sections 304A (causing death by negligence) and 34 (common intention) of the Indian Penal Code, 1860.
Adults, a public beach and no mens rea
All 41 students who entered the sea were adults, the Court held, and without mens rea the deaths amounted to a simple accident.
“However in the case of students who are major and above 18 years of age and that too in a public place and public beach, in my opinion, in the absence of mens rea it would be a case of simple accident.”
The occupier principle, as applied by the Court, put the duty on the State.
“If there is any degree of difficulty to a visitor meeting with an accident in a public place for example, a public beach then in that case it would be the State Government who would be responsible for the accident in question for not providing adequate life saving amenities, warnings, signages, life guards etc. on the public beach.”
“Applicants cannot be held criminally negligent for an unforeseeable event occurring beyond their direct control or operational purview.”
Accompanying teachers are expected to exercise some degree of supervision, the Court said, but what is crucial is the absence of mens rea and of a proximate negligent act. It found no material showing gross or high degree of negligence and allowed all four applications.
The picnic of February 1, 2016
Abeda Inamdar Senior College of Arts, Science and Commerce, Pune, took 116 students along with faculty and staff on a picnic to Murud beach in Raigad on February 1, 2016. At around 3:30 to 4:00 pm, 41 students of the Third Year batch went into the sea, and about 20 to 22 of them were swept away by an undercurrent. One student rescued about six with the help of local persons, but 14 students, that student included, lost their lives.
An initial enquiry was held under ADR No. 04 of 2016, and the FIR was registered around 80 days later, on April 19, 2016, on the complaint of the father of one of the deceased students.
What the parties argued
Vicarious liability could not be fastened on the trustees and the in-charge principal, they argued, the ingredients of Section 304A were not made out, and parents had signed No Objection Certificates. Teachers and staff attached to the First and Second Year batches said they had no responsibility for the Third Year students.
The State contended that the deaths resulted from negligence, including a failure to stop students from entering the sea. The complainant alleged that the trip date was changed unilaterally, that no doctor or sea swimmer accompanied the group and that the staff rested at a hotel about 500 metres from the beach, and sought a full trial. These remain allegations, and the Court found no material to proceed on them.
Drowning precedents, mostly of minors
Section 304A punishes causing death by a rash or negligent act. Justice Jadhav examined the Supreme Court’s decisions in M.S. Grewal v. Deep Chand Sood, where 14 minor school students drowned in a river during a picnic, and Jacob Mathew v. State of Punjab, on the gross negligence needed for criminal liability. He also looked at the Karnataka High Court’s ruling in Melvin Kumar v. K.S. Harisha, which dealt with a school picnic drowning at a resort swimming pool and treated the occupier of the premises as the party owing the duty of care.
Most precedents involve minors, who need much stricter supervision, the Court observed, and it said it was filling a gap where the victims were adults.
Signs, lifeguards and a policy for beaches
The State, through its Ministry of Tourism, was directed to map crowded beachfronts and frame a uniform policy for warning signs in English and Marathi showing hazards and high tide timings. Funds are also to be sanctioned for lifeguards and their regular training, protective grills, watchtowers, demarcated safe swimming zones, red flags during high tide, patrol vehicles and expert agencies.
A Government Order on beach safety was issued in 2006, the Court recalled, and a public interest litigation filed in 2010, revived after the Murud incident, was disposed of on November 13, 2019 on the State’s assurances. Noting that eight students of a coaching institution were recently swept away at a Raigad beach, it said:
“We cannot have a knee jerk reaction after every mishap.”
A copy of the judgment is to be sent to the Chief Secretary of the State.
Civil duty and criminal liability
For institutions that organise outings for adult students, civil and criminal responsibility are kept apart by the ruling. Section 304A needs a negligent act that is the proximate cause of death, and supervision duties owed to minors do not automatically carry over to adults at a public place.
The State’s duty as the provider of public beaches also comes into focus, and the Court asked for lasting safety measures instead of reactions after each tragedy. The FIR stands quashed, and the Court’s observations on civil liability, if any, were not part of these applications.
Case Title: P.A. Inamdar and Others v. State of Maharashtra and Another
Case Number: Criminal Application No. 493 of 2016, with Nos. 568, 569 and 975 of 2016
Bench: Justice Milind N. Jadhav, Bombay High Court
Date of Judgment: October 22, 2026
Appearances: Advocates Niranjan Mundargi with Keral Mehta (trustees and in-charge principal); Advocates Sidheshwar Biradar with Dinesh R. Shinde and Omhari B. Fawade (teachers and staff); APP Rajeshree V. Newton (State); Advocate Abhishek Pungliya (complainant)