Introduction:

In an important judgment addressing the growing number of petitions filed by interfaith and intercaste couples seeking continuous police protection, the Madhya Pradesh High Court has clarified that extraordinary security arrangements cannot be granted merely on the basis of apprehensions or isolated suspicious incidents. The ruling came in X v. State of Madhya Pradesh, W.P. No. 14252/2026, where the Court dismissed a writ petition filed by an interfaith married couple seeking round-the-clock police protection, including deployment of armed security personnel during night hours.

The case was heard by Justice Jai Kumar Pillai, who observed that while the constitutional right to life and personal liberty under Article 21 of the Constitution remains paramount, courts cannot mechanically issue directions for permanent armed protection without clear and unimpeachable evidence of an imminent and continuing threat. The Court remarked that an increasing number of couples entering intercaste or interreligious marriages were approaching constitutional courts seeking extensive police protection, often without placing sufficient material on record to justify such extraordinary relief.

The petitioners in the present case were a married couple who had solemnised their marriage in 2019 according to Hindu rites and customs. According to the pleadings before the Court, the wife had originally belonged to the Muslim faith but had voluntarily converted to Hinduism of her own free will before entering into marriage with the husband. The couple alleged that after the wife informed her parents and relatives about the marriage and religious conversion, they began receiving severe threats from family members opposed to the relationship.

The matter had a prolonged background of litigation and police correspondence. The petitioners claimed that the husband’s life had been threatened by persons belonging to another religion due to the interfaith marriage, a concern which was allegedly acknowledged by an investigating officer in a communication dated September 28, 2021. Fearing for their safety, the couple shifted their residence to Ratlam. Earlier, in 2022, the High Court had directed the Superintendent of Police, Ratlam, to consider the petitioners’ representation seeking protection, following which certain security arrangements were reportedly made.

However, the present dispute arose after the petitioners alleged that the security cover previously granted to them had been diluted. Specifically, they challenged an administrative action dated April 13, 2026, through which an armed gunman stationed outside their residence was allegedly withdrawn and replaced by an unarmed Home Guard personnel. According to the petitioners, the new arrangement was grossly inadequate because the Home Guard personnel neither possessed firearms nor had access to communication devices capable of summoning emergency assistance.

The petitioners further alleged that threats against them had escalated between 2024 and 2026. They referred to incidents involving suspicious vehicles, unidentified individuals allegedly conducting surveillance near their residence, and unknown persons roaming around their locality on motorcycles without registration plates. The petitioners argued that these circumstances clearly demonstrated a continuing threat to their lives and justified enhanced police protection.

The case therefore raised important constitutional and administrative law questions regarding the extent of the State’s duty to protect citizens under Article 21, the limits of judicial intervention in security deployment matters, and the evidentiary threshold required for courts to grant continuous police protection through writ jurisdiction.

The judgment assumes wider significance because it reflects judicial concern regarding the increasing tendency of litigants to seek indefinite and highly specific security arrangements through constitutional remedies. At the same time, the Court also acknowledged that police authorities continue to bear a constitutional and statutory obligation to respond effectively whenever credible complaints of threats or danger are received.

Arguments of the Parties:

The petitioners approached the Madhya Pradesh High Court seeking comprehensive reliefs aimed at securing enhanced police protection for themselves and their family members. Their principal grievance was directed against the decision of the authorities to withdraw the armed gunman earlier deputed for their protection and replace him with an unarmed Home Guard personnel.

Counsel appearing for the petitioners argued that the couple had been facing continuous threats ever since their interfaith marriage in 2019. It was submitted that the wife had voluntarily converted to Hinduism before solemnising the marriage according to Hindu rites and customs. However, once her family members came to know about the marriage and conversion, they allegedly began issuing threats and expressing hostility toward the couple.

The petitioners relied heavily upon previous police communications acknowledging the existence of a threat perception. In particular, reference was made to a communication issued by the investigating officer in September 2021, wherein it was allegedly noted that the husband faced threats from individuals belonging to another religion because of the interfaith marriage.

According to the petitioners, despite relocating to Ratlam in an effort to avoid danger, the threats continued unabated. They argued that suspicious incidents near their residence had increased significantly between 2024 and 2026. Counsel referred to an incident in 2024 where an unidentified person allegedly attempted to stop the couple’s vehicle and was seen surveying their residence. The petitioners also relied upon reports made by police personnel stationed near their house, including a constable’s report from October 2025 stating that unidentified individuals riding a motorcycle without a registration number were conducting surveillance around the property.

The petitioners contended that the immediate cause for approaching the Court arose after the respondents replaced the armed gunman stationed at their residence with an unarmed Home Guard personnel in April 2026. According to the petitioners, the replacement was arbitrary and unjustified, particularly because the Home Guard personnel lacked both firearms and basic communication facilities necessary for emergency response.

Counsel argued that the existing security arrangement was wholly inadequate considering the serious threat perception faced by the couple. It was submitted that the State bears a constitutional obligation under Article 21 of the Constitution to safeguard the lives and liberty of citizens. Therefore, failure to provide effective and continuous protection amounted to a violation of the petitioners’ fundamental rights.

The petitioners sought multiple directions from the Court, including quashing or modification of the impugned administrative action dated April 13, 2026, restoration of armed security personnel, deployment of adequate police force during night hours, and round-the-clock protection at their residence and wherever they travelled.

On the other hand, the State opposed the petition and resisted the attempt to secure judicial directions regarding the exact nature and extent of police deployment. The respondents argued that security arrangements fall within the domain of the executive and law enforcement agencies, which are required to assess threat perception based upon available intelligence and practical considerations.

The State contended that the petitioners had failed to produce clear, substantive, and unimpeachable evidence demonstrating any imminent and continuing threat justifying extraordinary protection measures. According to the respondents, vague apprehensions, suspicious vehicles, and isolated incidents of surveillance could not automatically entitle individuals to permanent armed security.

The respondents further argued that the earlier order passed by the High Court in 2022 did not confer any perpetual right to police protection upon the petitioners. The previous order had merely directed the Superintendent of Police to consider the petitioners’ representation in accordance with law. It did not amount to a judicial mandate requiring indefinite or round-the-clock security arrangements.

The State also emphasised that decisions regarding deployment of armed personnel, allocation of security resources, and assessment of threat perception are administrative matters requiring professional expertise. Courts, according to the respondents, should refrain from micromanaging security arrangements or substituting their own views for those of the police administration.

The respondents maintained that while the police authorities remain duty-bound to respond promptly to any genuine complaint of threat or harassment, the petitioners could not insist upon a specific mode of protection or demand permanent armed guards as a matter of right.

Court’s Judgment:

After examining the material placed on record and considering the submissions advanced by both sides, the Madhya Pradesh High Court dismissed the writ petition and declined to issue directions for continuous armed police protection. The judgment authored by Justice Jai Kumar Pillai laid considerable emphasis upon the need for strict scrutiny in cases seeking extraordinary security arrangements through writ jurisdiction.

At the outset, the Court observed with concern the increasing trend of couples involved in intercaste or interfaith marriages filing writ petitions seeking permanent police protection without placing clear and convincing evidence of imminent danger on record. The Bench remarked that constitutional courts were witnessing a growing number of such petitions where reliefs for round-the-clock security deployment were sought merely on the basis of general apprehensions.

The Court acknowledged that the right to life and personal liberty under Article 21 of the Constitution is one of the most fundamental constitutional guarantees. However, the Bench clarified that invocation of Article 21 does not automatically entitle a petitioner to indefinite police deployment or armed protection in the absence of credible material establishing a continuing threat.

Justice Jai Kumar Pillai observed that issuance of a continuous writ of mandamus directing deployment of specific security arrangements requires strict judicial scrutiny. According to the Court, every plea seeking such extraordinary relief must be substantiated by “clear, substantive, and unimpeachable evidence” demonstrating the existence of an ongoing and imminent threat.

Importantly, the Court held that isolated incidents such as suspicious vehicles, unidentified persons roaming nearby, or vague apprehensions cannot by themselves justify judicial directions for continuous armed security. The Bench observed that such circumstances may warrant ordinary police patrolling, inquiry, or investigation, but they do not necessarily establish a case for permanent personal protection.

In one of the most significant portions of the judgment, the Court cautioned against judicial overreach into matters concerning security administration. The Bench expressly stated that courts cannot assume the role of security establishments by dictating the precise modalities of police deployment.

The Court observed that it cannot issue blanket directions requiring the State to provide round-the-clock protection at residences or during movement of individuals, nor can it order allocation of specific categories of security personnel such as armed gunmen. Decisions regarding the nature of security arrangements, according to the Bench, lie primarily within the domain of the executive and law enforcement agencies.

The Court also rejected the petitioners’ attempt to rely upon the earlier order passed by the High Court in 2022. Justice Pillai clarified that the earlier order merely directed the Superintendent of Police to consider the petitioners’ representation in accordance with law within a specified period. It did not create any vested or perpetual right to continuous police protection.

The Bench specifically observed that the petitioners were incorrectly interpreting the earlier order as a judicial mandate for indefinite security cover. The Court made it clear that administrative decisions regarding continuation, modification, enhancement, or withdrawal of security arrangements remain subject to periodic review by competent authorities based on prevailing threat assessments.

At the same time, however, the Court acknowledged the continuing constitutional and statutory obligations of the police administration. The Bench emphasised that police authorities are duty-bound to maintain law and order and must act promptly and effectively whenever credible complaints of threats or harassment are received.

The judgment therefore struck a balance between two competing considerations. On one hand, the Court refused to convert generalized fears into a basis for indefinite judicially supervised security arrangements. On the other hand, it reaffirmed the responsibility of the State machinery to respond actively whenever genuine threats arise.

The Court’s reasoning also reflects broader constitutional principles governing separation of powers and judicial restraint. By declining to micromanage security deployment, the Bench recognised that decisions involving allocation of police resources require specialised expertise, practical assessment, and administrative discretion which courts are ordinarily ill-equipped to supervise on a continuous basis.

The ruling further reinforces the principle that extraordinary constitutional remedies cannot be granted solely on sympathetic considerations. Even in sensitive cases involving interfaith marriages, courts require objective material demonstrating immediate danger before directing extensive security arrangements at public expense.

At a broader societal level, the judgment is likely to generate discussion regarding the challenges faced by interfaith and intercaste couples in India. While the Court did not deny the possibility that such couples may genuinely face threats from hostile family members or communities, it insisted that judicial intervention must remain evidence-based rather than assumption-driven.

Ultimately, the High Court concluded that the specific reliefs sought by the petitioners, particularly those requiring detailed judicial control over security deployment, could not be granted within the framework of writ jurisdiction. Accordingly, the petition was dismissed.

The decision thus stands as an important precedent concerning the limits of judicial intervention in police protection matters and clarifies that while Article 21 guarantees protection of life and liberty, it does not automatically translate into a judicially enforceable right to permanent armed security in the absence of compelling evidence of imminent threat.