Supreme Court acquits school officials in Maharashtra tribal girl’s death in 2020 pillar collapse

The Supreme Court set aside the Bombay High Court’s order and acquitted two school officials of culpable homicide charges. They were Matin Shankarrao Bhosale, the school’s president, and its hostel superintendent. The ruling matters because criminal responsibility requires more than showing that officials failed to meet a required safety standard.

The officials were accused after a pillar collapsed at Prashnachinha Adivasi Ashram Shala in Maharashtra. Police charged them under Section 304, read with Section 34 of the IPC. The High Court had relied on evidence of inadequate cement and a missing solid base. The Supreme Court found that these facts did not establish the officials’ intention or knowledge that death was likely.

The court also noted that construction had been entrusted to a contractor. It said the officials’ alleged failure to ensure proper construction was not the direct and proximate cause of the girl’s death. The judgment therefore ended the culpable-homicide proceedings against them, while identifying the contractor as the person more directly connected, subject to evidence.

Bharti Belsare was a 12-year-old Class 7 student at Prashnachinha Adivasi Ashram Shala in Maharashtra’s Amravati district. She died on February 15, 2020, during an incident at the tribal residential school. Her death was caused by a cement-and-brick pillar that collapsed onto her.

The pillar was allegedly poorly constructed. The High Court noted forensic findings showing inadequate cement content and no proper solid base. These construction defects formed part of the prosecution’s case against the school officials. Several other girls were also injured when the structure collapsed.

Bharti’s father, who was a labourer, lodged the first information report. He alleged that the school president and hostel superintendent allowed substandard construction and failed to take adequate precautions. The Supreme Court did not dispute that Bharti died in the collapse. Instead, it held that the officials’ alleged failures were not shown to be the immediate and effective cause required for criminal liability.

The incident caused one confirmed death: Bharti Belsare, a 12-year-old student. The article also reports that several other girls were injured when the pillar collapsed. It does not provide an exact injury count, so the total number of injured people cannot be stated more precisely.

Two school officials were charged in connection with the death. They were Matin Shankarrao Bhosale, the school president, and the hostel superintendent. Police filed a chargesheet against them under Section 304 of the IPC, read with Section 34, alleging culpable homicide not amounting to murder and joint criminal liability.

The Supreme Court later acquitted both officials of those charges. Its ruling did not change the reported number of victims from the collapse. The judgment focused on whether the officials’ conduct met the legal threshold for criminal liability, and the court said the contractor was more directly connected to the construction work, subject to evidence.

Section 304 of the IPC concerns culpable homicide not amounting to murder. The prosecution must show intention to cause death, or knowledge that the act was likely to cause death. This is a serious form of criminal liability because the accused’s state of mind is central to the charge.

Section 304A applies when death results from a rash or negligent act, but there is neither an intention to cause death nor knowledge that death would probably result. The Supreme Court stressed that ordinary negligence is not automatically criminal negligence. The conduct must involve gross and culpable neglect or failure to take precautions that were imperative.

The distinction mattered in Bharti’s case. The court said inferior construction material, by itself, did not prove that the officials knew a student was likely to die. It also said criminal negligence requires the accused’s act to be the direct and proximate cause of death, not merely one contributing circumstance.

The Supreme Court applied the principle of causa causans, meaning the immediate and effective cause of death. It said criminal liability cannot rest merely on an act being one necessary condition in a chain of events. The prosecution had to connect the officials’ own conduct directly to Bharti’s death.

The officials did not carry out the construction themselves. The actual work had been entrusted to a contractor and his team. The court said that if the contractor had taken adequate care to protect the students, the collapse might not have happened. It also noted that many other factors might have contributed to the incident.

For that reason, the alleged failure to ensure proper construction was not treated as the direct and proximate cause. The court did not say the collapse was harmless or that no one could be responsible. It held only that this causal and legal link was insufficient for criminal proceedings against these officials under the circumstances described.

The contractor’s responsibility arose from performing the construction work itself. The school officials had entrusted the pillar’s construction to the contractor and his team. That made the contractor the person more directly involved in the materials, methods, structural work, and immediate safety measures during construction.

The court’s example was practical: if the contractor had taken adequate care to ensure the students’ safety, the incident might not have occurred. The pillar was found to have inadequate cement content and no proper solid base, according to the High Court’s account. Those facts pointed toward construction and execution issues.

The Supreme Court therefore said the contractor could prima facie be held responsible for Bharti’s death, subject to evidence. This did not automatically establish the contractor’s guilt. It explained why the school officials, who were not carrying out the construction, could not be treated as the direct cause merely because they allegedly failed to ensure proper construction.

Criminal liability for a death is more serious than simply finding that someone failed to meet a safety standard. The law therefore asks whether the person intended the result, knew death was likely, or showed gross and culpable neglect. This helps distinguish a crime from an ordinary mistake or civil breach of duty.

In this case, the Supreme Court said the officials’ failure to ensure proper construction did not prove that they knew the pillar was likely to kill a student. It also stressed that mere negligence cannot be treated as rashness. Even a Section 304A case requires a serious failure to take precautions that were imperative.

The rule also requires a direct causal link. The accused person’s conduct must be the immediate and effective cause, not simply one background condition. This protects against imposing criminal punishment on people whose connection to a fatal event is too indirect, while leaving room for liability where evidence shows intention, knowledge, or gross neglect.