Introduction:
The Punjab and Haryana High Court, while hearing the Public Interest Litigation titled Kanwar Pahul Singh v. State of Punjab, took serious note of growing concerns regarding fire safety in coaching centres and educational institutions across Punjab following the devastating fire at a coaching centre in Lucknow that claimed the lives of eighteen people, most of them students. A Division Bench comprising Acting Chief Justice Ashwani Kumar Mishra and Justice Rohit Kapoor observed that the incident was deeply disturbing and warranted immediate attention from the State authorities. Although the Court refrained from expressing any opinion on the merits of the allegations raised in the petition, it directed the Punjab Government to place on record a comprehensive status report detailing the measures taken to ensure fire safety and protect students from similar tragedies.
The Public Interest Litigation was filed against the backdrop of a tragic incident reported in The Tribune on June 23, 2026, under the headline “Lucknow coaching centre blaze leaves 18 dead, majority of victims students.” According to the report, a massive fire broke out at approximately 2:30 p.m. in a multi-storey commercial building situated in Aliganj, Lucknow. The building housed several educational and commercial establishments, including a coaching centre, a library, an animation training institute, and other businesses. Thick smoke rapidly spread through the upper floors, trapping students and trainees who were attending classes inside the premises. The fire resulted in the deaths of eighteen persons and caused injuries to several others, highlighting serious concerns regarding compliance with fire safety regulations in educational establishments.
Preliminary investigations, as referred to in the petition, indicated multiple violations of statutory requirements. The building was reportedly sanctioned only for residential purposes but had subsequently been converted into a four-storey commercial establishment without obtaining mandatory approvals from the fire department or the electricity authorities. It was also alleged that the premises exceeded its sanctioned electricity load and lacked essential fire safety infrastructure such as adequate firefighting equipment, emergency exits, and evacuation systems. These allegations raised broader concerns regarding regulatory enforcement and the responsibility of public authorities to ensure compliance with safety norms before permitting commercial educational activities.
The petitioner also relied upon another report published on June 24, 2026, which referred to surprise inspections conducted by the Municipal Corporation’s Fire and Rescue Services Department. These inspections allegedly revealed significant fire safety deficiencies in several coaching centres, thereby suggesting that the problem was not confined to a single institution but reflected a larger pattern of non-compliance affecting educational establishments.
The litigation was not merely confined to the facts of the Lucknow incident. It raised wider constitutional concerns regarding the duty of the State to protect the lives and safety of students studying in private coaching institutions and educational facilities. The petitioner argued that every educational institution accommodating large numbers of students must strictly comply with fire safety regulations, building norms, and emergency preparedness requirements. The petition further relied upon directions previously issued by the Supreme Court concerning fire safety in schools, which mandate adherence to the National Building Code, installation of appropriate firefighting equipment, periodic structural inspections, and regular emergency preparedness training for staff and management.
Considering the gravity of the issues raised, the High Court sought to examine whether adequate preventive mechanisms presently exist in Punjab to avoid similar incidents. The Court therefore required the State Government to disclose the steps already taken to ensure that coaching centres and educational institutions operate in accordance with applicable fire safety laws and building regulations.
Arguments of the Parties:
The petitioner, Kanwar Pahul Singh, approached the Punjab and Haryana High Court through a Public Interest Litigation highlighting the urgent necessity of strengthening fire safety measures in coaching centres and educational institutions across Punjab. The petition was founded primarily upon recent media reports documenting the fatal coaching centre fire in Lucknow, where eighteen persons, most of them students, lost their lives after being trapped inside a smoke-filled multi-storey building.
The petitioner contended that the Lucknow tragedy demonstrated how widespread violations of fire safety regulations, building bye-laws, and electricity norms can have catastrophic consequences. It was submitted that the building in question had allegedly been converted from residential to commercial use without obtaining mandatory statutory approvals, thereby exposing students to grave and avoidable risks.
The petitioner further argued that similar deficiencies may exist in coaching centres functioning within Punjab. Relying upon subsequent news reports concerning inspections conducted by Fire and Rescue Services authorities, it was submitted that several coaching institutions had been found violating mandatory fire safety requirements. These reports, according to the petitioner, justified immediate judicial intervention to ensure that educational institutions across the State comply with applicable safety standards before another preventable tragedy occurs.
The petitioner also placed reliance upon the principles laid down by the Supreme Court in its landmark decisions concerning fire safety in schools and educational institutions. It was submitted that the Supreme Court has consistently emphasized strict compliance with the National Building Code, installation and maintenance of firefighting equipment, periodic structural safety audits, emergency evacuation plans, and training of staff members in disaster management. According to the petitioner, these judicial directions should equally apply to coaching centres, libraries, and similar educational establishments where large numbers of students gather daily.
The petitioner therefore requested the Court to issue appropriate directions requiring State authorities to conduct inspections, ensure compliance with statutory norms, and establish effective mechanisms capable of preventing fire-related disasters in educational institutions.
On behalf of the State of Punjab, the State counsel submitted that adequate administrative mechanisms were already in place to address fire safety concerns. It was informed that a nodal officer had been appointed specifically to coordinate and oversee issues relating to fire safety compliance. The State further submitted that a separate statutory framework already governs fire safety requirements applicable to buildings and educational institutions.
According to the State, the existing regulatory mechanism adequately addresses fire prevention and emergency preparedness. The Government therefore sought to assure the Court that necessary institutional arrangements were functioning and appropriate safeguards had already been established under the applicable statutory regime.
However, upon the Court expressing concern regarding the Lucknow incident and seeking further particulars, the State did not oppose the direction for filing a detailed status report and agreed to place comprehensive information before the Court regarding the measures presently implemented to safeguard students from fire-related hazards.
Court’s Judgment:
The Punjab and Haryana High Court treated the issues raised in the Public Interest Litigation with considerable seriousness, observing that the tragic fire incident in Lucknow had highlighted the pressing need to examine fire safety standards in educational institutions across Punjab. While refraining from expressing any conclusive opinion on the merits of the allegations contained in the petition, the Division Bench recognised that the issues involved directly concern the safety and lives of students attending coaching centres and similar establishments.
The Court briefly but significantly remarked that “what has happened is worrisome,” thereby acknowledging the alarming nature of the incident and the necessity for preventive action. Rather than limiting its consideration to the individual tragedy that occurred in another State, the Court adopted a broader preventive approach by seeking to ascertain whether adequate safeguards presently exist within Punjab to prevent similar incidents from occurring.
An important feature of the Court’s approach was its emphasis on prevention rather than post-incident accountability. The Bench recognised that judicial intervention in matters concerning public safety should ideally focus upon identifying institutional shortcomings before lives are lost rather than merely reviewing governmental action after disasters occur. This preventive perspective is consistent with the constitutional obligation of the State to protect life under Article 21 of the Constitution, which has consistently been interpreted by constitutional courts as imposing positive obligations upon public authorities to safeguard citizens from foreseeable risks.
The Court also took note of the petitioner’s reliance upon earlier directions issued by the Supreme Court concerning fire safety in schools. Those directions emphasise strict compliance with the National Building Code, proper installation and maintenance of firefighting equipment, regular structural inspections, preparation of emergency evacuation plans, and periodic training of staff members in responding to fire emergencies. Although the present proceedings concerned coaching centres rather than formal schools, the principles underlying those directions remain equally relevant because both categories of institutions accommodate large numbers of students whose safety depends upon effective implementation of fire prevention measures.
The Bench also recognised the significance of the allegations relating to unauthorized construction and regulatory violations referred to in the Lucknow incident. The reported conversion of a residential building into a commercial educational establishment without obtaining mandatory no-objection certificates from the fire and electricity departments illustrates the potential consequences of weak regulatory enforcement. While the Court did not undertake any factual determination regarding those allegations, it considered the incident sufficiently serious to justify seeking information regarding Punjab’s own regulatory framework and enforcement mechanisms.
The Court further acknowledged the State’s submission that statutory provisions governing fire safety already exist and that a nodal officer has been appointed to coordinate implementation of safety measures. However, instead of accepting these submissions at face value, the Court required the Government to substantiate its claims by placing concrete details before the Bench through a formal status report.
Accordingly, the Court directed the Punjab Government to file a comprehensive status report indicating the measures undertaken by the authorities to protect innocent students from fire incidents. The report is expected to inform the Court about the existing regulatory framework, inspection mechanisms, enforcement measures, compliance monitoring, and any additional steps taken following the recent tragedy to ensure that coaching centres and educational institutions function in accordance with fire safety laws.
Importantly, the Bench clarified that its observations should not be construed as expressing any opinion regarding the merits of the Public Interest Litigation or the adequacy of the present statutory framework. The Court confined itself to directing the State to disclose factual information necessary for evaluating whether existing safety measures are sufficient to protect students.
By requiring the Government to place its preparedness and regulatory mechanisms on record, the Court reaffirmed the principle that public authorities remain accountable for ensuring compliance with statutory safety requirements in buildings where educational activities are conducted. Such accountability extends beyond mere enactment of laws and includes effective implementation, periodic inspections, timely enforcement, and continuous monitoring of compliance.
The proceedings therefore reflect the judiciary’s proactive role in safeguarding public safety through preventive oversight. Instead of waiting for a similar tragedy to occur within the State, the High Court has chosen to examine whether the administrative machinery responsible for enforcing fire safety regulations is functioning effectively. Such judicial scrutiny encourages transparency, strengthens institutional accountability, and promotes greater compliance with statutory obligations governing educational infrastructure.
The matter has now been listed for further hearing on 10 August 2026, when the State Government is expected to place its status report before the Court. The outcome of the proceedings may have significant implications for the regulation of coaching centres and educational institutions in Punjab, particularly regarding fire safety compliance, building approvals, emergency preparedness, and administrative enforcement. The case also serves as a reminder that the constitutional guarantee of the right to life encompasses not merely protection against unlawful deprivation of life but also the duty of the State to create and enforce safety mechanisms capable of preventing avoidable disasters in places where students pursue their education.