Kerala High Court Upholds Teacher's Right to Reasonable Disciplinary Action in Schools

Teacher's Corporal Punishment Deemed Lawful Under Implied Parental Consent and Good Faith

In a landmark decision, the Kerala High Court has ruled in favor of a school teacher accused of corporal punishment, emphasizing the lawful boundaries within which teachers can enforce discipline. The case, Abhuthahir v. State of Kerala, centered on allegations against a teacher who used a cane to separate and discipline students engaged in a physical altercation at Mambad CAUP School.

The incident occurred on September 16, 2019, when students in a 5th-grade class began attacking each other with sticks. The teacher, identified as the petitioner, intervened by caning the students on their legs to restore order. The case was brought forward by the parents of the affected students, alleging violations under Section 324 of the Indian Penal Code and Section 75 of the Juvenile Justice (Care & Protection of Children) Act, 2015.

Presiding Judge Mr. C. Pratheep Kumar, in his order dated October 16, 2025, quashed the proceedings against the teacher. The court held that the teacher's actions were within the legal framework and did not constitute an offense as they were performed with bona fide intention and minimal force. The judgment emphasized that such actions, when done in good faith and without causing unnecessary harm, are protected under Sections 88, 89, 79, and 80 of the Indian Penal Code, which allow for reasonable disciplinary measures by individuals in loco parentis.

The court further noted that the delay in reporting the incident and the absence of medical evidence of injury supported the teacher's claim of using minimal force. It was also highlighted that the parents, by entrusting their children to the school, implicitly consent to reasonable disciplinary measures necessary for maintaining school discipline.

The judgment referenced previous decisions, including K.A. Abdul Vahid v. State of Kerala and Rajan @ Raju v. Sub Inspector of Police Farook Police Station, reinforcing the principle that teachers have the authority to discipline students, provided it is done with the intent of improving student behavior and within reasonable limits.

This decision is expected to have significant implications for the educational community, reaffirming the legal protections available to teachers in the exercise of their disciplinary duties.

Bottom Line:

A teacher's act of corporal punishment for maintaining discipline and correcting students is lawful, provided it is done with bona fide intention, using minimum force, and without causing harm beyond what is necessary for discipline.

Statutory provision(s): Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528, Juvenile Justice (Care & Protection of Children) Act, 2015 Section 75, Indian Penal Code, 1860 Sections 324, 88, 89, 79, 80.

Abhuthahir v. State of Kerala, (Kerala) : Law Finder Doc Id # 2797189