At Least 50 Orders in Six Months: How One Orissa High Court Judge Made Cleaning Police Stations, Hospitals and Temples a Bail Condition

Odisha: Between April and September 2025, Justice S.K. Panigrahi of the Orissa High Court passed at least 50 bail orders directing accused persons to clean police stations, temples, hospitals, village roads, local ponds, and, in one instance, a bank branch—a practice that has now drawn the attention of the Supreme Court of India.

On 02 May 2026, the Supreme Court initiated a suo motu case concerning courts in Odisha imposing cleaning duties as a condition for bail. While recent reports suggested such orders were confined to cases involving anti-mining protestors, a review of e-Courts records shows that Justice Panigrahi had been passing such orders across a wide range of criminal cases—from theft to murder—for at least six months.

Records available on the e-Courts portal show that no other judge of the Orissa High Court appears to have passed bail orders with such conditions.

Justice Panigrahi issued these directions across a variety of cases. Every order specified the time at which the accused was required to perform cleaning duties, usually for two to three hours, typically between 6:00 AM and 10:00 AM, and the period for which the condition would operate, typically between one and three months.

Of the 50 orders analysed, 32 directed accused persons to clean police station premises. Eleven orders directed accused persons to clean hospitals or health centres. The remaining orders covered temples, a pond, a post office, a community health centre, and a bank branch.

No consistent proportionality was observed between the nature of the alleged offence and the cleaning condition imposed. Accused persons in murder cases and theft cases received the same community service direction, albeit after undergoing different periods of incarceration.

In some cases, however, an evident connection existed between the alleged offence and the direction. Persons accused of stealing from temples were ordered to clean those same temples. A person accused of committing an act of bestiality was directed to clean the village road and collect and dump cow dung at a specified location every day for a month.

In one case, a woman accused of cheating and failure to repay loans was ordered to clean the premises of the concerned ICICI Bank branch at Link Road, Cuttack, for two months. This was the only instance in which the condition was subsequently deleted after the accused informed the Court of spinal issues that prevented her from spending extended hours bending over to clean floors.

One of the 50 orders was issued on the bail application of Kumeswar Naik, an anti-mining protestor who faced several charges, including rioting and attempt to murder. The Court granted bail after Naik had spent just over three months in custody, directing him, as a condition of bail, to clean the premises of Kasipur Police Station between 6:00 AM and 9:00 AM for two months from the date of his release.

A report by Article 14 had highlighted eight such orders, seven passed by district courts and one passed by the Orissa High Court in Naik’s case, imposing cleaning conditions on persons involved in anti-mining protests in the State. Many of the accused persons in those cases are from Dalit and Adivasi communities. Legal experts have questioned the propriety of such bail conditions, and social activists have pointed to the appearance of a caste bias in such orders.

There is no statutory provision that permits the imposition of cleaning duties as a condition for the grant of bail. The Bharatiya Nyaya Sanhita recognises community service as a distinct form of punishment for certain offences, but strictly as a penal provision applicable to convicted persons, not as a bail condition. The Kerala High Court, in a judgment delivered in June 2025, observed that community service as defined under Section 4(f) of the BNS is a punishment to be awarded in appropriate cases and cannot be imposed as a bail condition. The Supreme Court has also previously taken a dim view of the practice of imposing conditions unconnected to the object of bail while granting it.

List of 50 Order: