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Bombay High Court Upholds Binding Nature of MSHRC Recommendations

LAW FINDER NEWS NETWORK | February 16, 2026 at 11:31 AM
Bombay High Court Upholds Binding Nature of MSHRC Recommendations

Court Directs Maharashtra Government to Deposit Rs.3.60 Crores for Compensation Compliance


In a landmark judgment, the Bombay High Court has reinforced the binding nature of recommendations made by the Maharashtra State Human Rights Commission (MSHRC), directing the state authorities to comply with these recommendations unless they are challenged in review or appeal proceedings. The ruling came in response to a Public Interest Litigation filed by Satyam Atul Surana, asserting the statutory duty of state authorities under Section 18(e) of the Protection of Human Rights Act, 1993.


The bench, comprising Chief Justice Shree Chandrashekhar and Justice Gautam A. Ankhad, took cognizance of the PIL on November 18, 2025, with subsequent proceedings highlighting the delay and non-compliance by the state authorities concerning MSHRC's recommendations. Despite several adjournments, the state failed to provide concrete details or a comprehensive plan for compliance, prompting the court to take decisive action.


In its order dated January 27, 2026, the court mandated the Principal Secretary of the Home Department, Government of Maharashtra, to deposit a sum of Rs.3.60 crores with the court within two weeks. This amount is earmarked for compensation to victims or their legal heirs as recommended by MSHRC. Additionally, the court instructed the appointment of a Nodal Officer responsible for serving notices to all eligible recipients of compensation within 10 days, using both electronic and personal modes of communication.


The court's directive underscores the importance of statutory compliance with human rights commission recommendations, emphasizing that they possess binding force unless legally contested. This decision is expected to set a precedent for similar cases across the country, reinforcing the authority of human rights commissions and ensuring accountability of state agencies in safeguarding human rights.


The court has scheduled the next hearing on February 17, 2026, to review the progress of compliance with its orders.


Bottom Line:

Recommendations of the Maharashtra State Human Rights Commission (MSHRC) are binding in nature, provided they are not challenged in any review or appeal proceedings. State authorities are under a statutory duty to comply with such recommendations.


Statutory provision(s): Protection of Human Rights Act, 1993 Section 18(e)


Satyam Atul Surana v. State of Maharashtra, (Bombay)(DB) : Law Finder Doc id # 2847675

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