Neutral Citation No. 2026:JHHC:9192-DB

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IN THE HIGH COURT OF JHARKHAND AT RANCHI

W.P. (PIL) No. 920 of 2021

Onkar Vishwakarma, Aged about 33 years, S/o Harendra

Vishwakarma, R/o Ward No.6, P.O.+P.S.- Domchanch, Mahthadih,

Koderma, Jharkhand-825418

... Petitioner

Versus

1. State of Jharkhand through Secretary, Department of Health,

Medical Education and Family Welfare, Nepal House, Doranda,

P.O. & P.S-Doranda, District-Ranchi, Jharkhand

2. Deputy Commissioner, Hazaribagh, PO+PS- Sadar, Hazaribagh.

3. District Supply Officer, Hazaribagh, PO+PS- Sadar, Hazaribagh.

4. Civil Surgeon, Sadar Hospital, Hazaribagh, PO+PS- Sadar,

Hazaribagh.

... Respondents

---------

CORAM: HON’BLE THE CHIEF JUSTICE

HON’BLE MR. JUSTICE RAJESH SHANKAR

---------

For the Petitioner: Ms Diksha Dwivedi, Amicus Curiae

For the Respondents: Mr Piyush Chitresh, A.C. to A.G.

---------

Reserved on: 26.03.2026 Pronounced on: 01/04/2026

Per M. S. Sonak, C.J.

1. We have heard the learned counsel for the parties.

2. The present writ petition has been filed in purported public

interest, seeking, inter alia, the following reliefs: —

a) For issuance of a writ in the nature of mandamus

directing the respondents to immediately put the

surviving victims of the kerosene fire and other burn

patients in the burn unit/department and, in the event

such facility is not available at Sadar Hospital,

Hazaribagh, to forthwith refer and admit such patients

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to the burn unit/department at Rajendra Institute of

Medical Sciences (RIMS), Ranchi;

b) For issuance of a writ in the nature of mandamus

directing the respondents to provide medical treatment

to all the victims free of cost, including medicines and

other related expenses, to be borne by the State

Government;

c) For issuance of a writ in the nature of mandamus

directing the respondents to pay compensation to the

legal heirs of persons who died in the kerosene fire

incident in the district of Hazaribagh, to the extent of Rs.

50,00,000/-;

d) For issuance of a writ in the nature of mandamus

directing the respondents to pay compensation to

persons who have suffered disability due to injuries in

the said incident, to the extent of Rs. 35,00,000/-;

e) For issuance of a writ in the nature of mandamus

directing the respondents to pay compensation to the

injured persons, including the ones who have incurred

facial disfigurement, in the said incident, to the extent of

Rs. 25,00,000/-.

3. This petition has been instituted in the backdrop of an

unfortunate incident resulting in multiple deaths, burn injuries and

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fatalities, allegedly caused due to the use of highly inflammable

kerosene supplied through the Public Distribution System in

Hazaribagh. The petitioner has brought to the notice of this Court that

several injured persons were admitted to Sadar Hospital, Hazaribagh,

and, according to the petitioner, were not receiving adequate treatment

owing to the absence of specialized burn care facilities.

4. It is the petitioner’s case that certain injured persons, including

members of the same family, were admitted in general wards and

required urgent transfer to dedicated burn units or to higher medical

centres such as Rajendra Institute of Medical Sciences (RIMS), Ranchi.

The petitioner has also alleged that essential medicines were not readily

available at the Sadar Hospital, Hazaribagh, and had to be procured

from outside sources.

5. The petitioner has further pleaded that, despite approaching the

concerned authorities, including the hospital administration and district

officials, no effective or timely action was taken to ensure proper

treatment for the victims or to address their grievances.

6. A significant aspect of the petitioner’s grievance pertains to the

nature of the commodity itself. It is pleaded that the kerosene supplied

to the victims was highly adulterated, rendering it unfit for domestic

use. Annexure 3, appended to the writ petition, contains the laboratory

reports, including those from the Indian Oil Corporation, which reveal

that the flash point of the said kerosene was a mere 13.5°C. This is

significantly below the prescribed safety minimum of 35°C. Such a

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deviation, according to the petitioner, effectively transformed a

domestic necessity into a lethal explosive.

7. Furthermore, the petitioner has detailed the devastating impact of

this systemic lapse. The tragedy resulted in four deaths, including a

two-year-old child and an elderly woman. Approximately fifteen other

persons, many of them women and minors, suffered grievous burn

injuries and permanent facial disfigurement. The petitioner contends

that these casualties were not the result of mere accidents, but a direct

consequence of the distribution of hazardous fuel through State-

authorized outlets.

8. It is also the petitioner's case that the victims’ families, already

suffering from the trauma of the incident, were forced to purchase life-

saving medicines from the open market. The petitioner argues that the

State, having failed to ensure the quality of a regulated commodity,

cannot further shirk its responsibility by providing inadequate medical

care.

9. Advancing these grievances, the petitioner has placed on record

photographs of the injured persons as contained in Annexure-4,

appended to the writ petition. It is also the contention of the petitioner

that the absence of functional district-level burn units is not merely an

administrative lapse, but a breach of the constitutional mandate to

protect the right to life with dignity of the injured persons.

10. Presumably, as the core issues raised by the petitioner pertain to

the non-implementation of safety standards for burn victims and the

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systemic deficiency in specialised healthcare, the present matter was

categorised and treated as a “Public Interest Litigation.”

11. Regarding the relief sought in prayer Clause (A), which requests

a writ for the immediate admission or transfer of the remaining victims

of the kerosene fire to a dedicated burn unit or to Rajendra Institute of

Medical Sciences (RIMS), Ranchi, it should be noted that this relief

was based on the circumstances prevalent at the time of the incident.

12. However, no further submissions have been advanced on behalf

of the petitioner during the hearing to indicate that such a situation

presently subsists. We also do not find any material on record, whether

in the pleadings or in the affidavits filed by the parties, to demonstrate

the victims' current status or the necessity of any immediate

intervention of the nature originally sought.

13. Having regard to the lapse of time, the incident being of the year

2021, and in the absence of any contemporaneous material justifying

the grant of such relief at this stage, we are of the view that the relief

sought in terms of prayer Clause (A) does not survive for consideration

and has, in effect, been rendered infructuous.

14. Insofar as the reliefs sought in terms of prayer Clauses (C), (D)

and (E) are concerned, namely, for issuance of directions to the

respondents to pay compensation to the legal heirs of the deceased and

to the injured victims in specified amounts, we note that such reliefs are

essentially in the nature of claims for monetary compensation arising

out of the incident in question.

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15. It is well-settled that the concept of compensatory jurisprudence

for the violation of fundamental rights is firmly entrenched in our

public law. In Rudul Sah v. State of Bihar, reported in (1983) 4 SCC

141, the Hon’ble Supreme Court first awarded monetary compensation

in a writ petition, holding that the Court is empowered to grant such

relief when there is an established violation of Article 21. This principle

was authoritatively crystallised in the case of Nilabati Behera v. State

of Orissa, reported in (1993) 2 SCC 746, in which the Hon’ble Apex

Court recognised the doctrine of ‘constitutional tort’ and clarified that

the defence of sovereign immunity is unavailable in such proceedings.

16. Thereafter, this principle of law has been consistently applied by

the Hon’ble Apex Court in the cases of D.K. Basu v. State of West

Bengal, reported in (1997) 1 SCC 416 and Chairman, Railway

Board v. Chandrima Das, reported in (2000) 2 SCC 465

respectively. These dicta of the Hon’ble SC establish that when the

State fails in its constitutional duty to protect life, the court may direct

monetary relief as an integral part of the enforcement of fundamental

rights. In the present case, the Hazaribagh tragedy, underscored by the

systemic absence of functional burn units, represents a prima-facie

breach of this mandate.

17. However, the grant of such compensation in a specific quantum

necessarily depends upon the determination of relevant facts. This

includes an assessment of the nature of the incident, the extent of

negligence, and the definitive identification of the responsible parties.

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These are matters which ordinarily require the adjudication of evidence

and cannot appropriately be undertaken in the present Public Interest

Litigation under Article 226 of the Constitution.

18. We also note that an FIR, bearing Mufassil P.S. Case No.

45/2021, has already been registered, and the matter is currently under

investigation or trial before the competent jurisdictional court. In such

circumstances, issuing a direction to pay specific, pre-determined

amounts of compensation would be premature at this stage.

19. At the same time, the victims cannot be left without a remedy. It

is necessary to take note of the statutory framework under S. 357-A of

the Code of Criminal Procedure, 1973, and the corresponding

provisions under Section 396 of the Bharatiya Nagarik Suraksha

Sanhita, 2023. These provisions establish a Victim Compensation

Scheme to provide immediate relief and rehabilitation to those who

have suffered loss or injury as a result of a crime.

20. Besides, the affected parties are always free to explore instituting

civil proceedings before the competent Courts to claim damages, etc.

The state must also consider whether any ad hoc payments can be made

to the identified victims or their legal representatives in such matters.

21. Accordingly, while we do not propose to grant the specific

monetary reliefs under prayer Clauses (C), (D), and (E) at this stage, we

clarify that the victims and their legal heirs remain entitled to invoke

these remedies. To ensure that this right does not remain illusory, we

shall issue appropriate directions in the concluding part of this

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judgment, mandating that the jurisdictional court and the concerned

District Legal Services Authority (DLSA) act with the requisite urgency

to provide necessary succour.

22. Moving ahead, while the petitioner’s initial grievances were

rooted in the specific tragedy at Hazaribagh, the proceedings in this

matter have brought to light a much larger, systemic deficiency. It is a

settled principle of PIL jurisprudence that once a matter of grave public

importance is brought before this Court, this Court may expand the

scope of the inquiry to ensure that the fundamental rights of a larger

class of citizens are protected. This Court, therefore, cannot remain a

mute spectator to a state-wide paralysis in specialized medical care.

23. In this context, it is pertinent to note that this Court, while

dealing with the present matter, identified the seminal public issue

concerning the plight of burn victims across the State. In the order

dated 22.07.2025, this Court took a proactive stance, observing that the

gravity of the subject matter outweighed any procedural defaults.

Paragraph 10 of the said order reads as follows:

“10. This Court, considering the nature of issue

involved in the present Public Interest Litigation, is of

the view that merely on account of non-appearance of

the learned counsel on record, it would not be proper

for this Court to close this Public Interest Litigation,

reason being, as has been admitted by the learned

State counsel also that the issue involved in the

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present case is quite serious and no specialized ward

with modern facilities to deal with the patients of burn

injury is available in the Government hospitals in the

entire State.”

24. This admission by the State, as recorded in our earlier

proceedings, strikes at the very heart of the “Right to Health” under

Article 21. If, as admitted, no specialised burn care facility with modern

infrastructure exists in the Government hospitals across the entire State

of Jharkhand, then the constitutional guarantee of life with dignity

remains largely illusory for victims of fire trauma.

25. Consequently, the focus of this litigation shifted from the

individual claims of the Hazaribagh victims to a broader mandate, i.e.,

the establishment of a robust, state-wide, specialised burn medical

infrastructure. The Hazaribagh incident served merely as the diagnostic

event that exposed this state-wide paralysis in burn care management.

26. Pursuant to the order dated 22.07.2025 passed by this Court, the

State was directed to file a consolidated and comprehensive counter-

affidavit. Upon perusal of the said affidavit, which came to be filed

after some delay, this Court, by its order dated 24.09.2025, made the

following observations:

1. Even though the respondents have filed a counter affidavit in

terms with the order passed by this Court on 17.09.2025,

however, astonished to note the mismatch in the burn wards

available in the five medical colleges and hospitals of the State

of Jharkhand (Annexure-C series to the said counter affidavit).

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2. It would be noticed that in the case of Shahid Nirmal Mahto

Medical College and Hospital, Dhanbad, the bed capacity of

the hospital in the burn ward is 14 as against which, 13

doctors and 7 staff nurses are posted there. In M.G.M. Medical

College and Hospital, Jamshedpur, as against the bed capacity

of 15, only one Associate Professor, 5 Junior Residents and 10

Staff Nurses are posted there. In Phulo-Jhano Medical College

and Hospital, Dumka, which has the bed capacity of 20, there

is no doctor and only 6 Staff Nurses are posted. Similarly,

Medininagar Medical College and Hospital, Palamu having

bed capacity of 10, there is only one staff and it is not known as

to whether the same is doctor or staff nurse. Lastly, in Sheikh

Bikhari Medical College and Hospital, Hazaribagh having bed

capacity of only 7, as many as 11 staff members are posted

there. We have specifically referred to as the 'staff' because it

is not known as to whether these 11 persons deputed there are

doctors or staff nurses or both as the case may be.

3. Likewise, the details regarding the government hospitals

have been given in Annexure-D series to the said counter

affidavit. On perusing along with the report of the Comptroller

and Auditor General of India on District Hospital Outcomes in

Jharkhand ((Report No. 3 of the year 2021) (Performance

Audit)]), it would be noticed that 'construction of 10 bedded

burn units with supply of furniture and equipment in all 24

districts were sanctioned (August, 2014) at Rs. 1.35 Crore

each. Among these, four units were dropped (January, 2016)

and 20 units were completed at Rs. 12.40 Crore (between

September, 2015 and January, 2017). However, the completed

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units could not be made functional due to non-procurement of

equipment.'

4. Annexure-D series as mentioned above does not contain a

single detail of any of these units. It is beyond comprehension

as to how these units vanished in thin air. This also assumes

importance because the operational guidelines for

establishment of burn units in district hospitals under National

Programme for Prevention & Management of Burn Injuries

were formulated by the Central Government in the 12th Five

Year Plan and we have been informed that the financial aid

was granted to five hospitals/medical colleges of the Jharkhand

viz. Patliputra Medical College and Hospital, Dhanbad

(6.1632 Crore), District Hospital, Koderma (4.942 Crore),

Sadar Hospital, Daltonganj (4.942 Crore) and District

Hospital, Gumla (4.942 Crore). Even these Trauma Care

Facilities, which were allocated the funds as aforesaid, do not

find mention in the Annexure-D series.

5. In the given facts and circumstances, we deem it appropriate

to direct the respondents to file a supplementary counter

affidavit clarifying the aforesaid position.

6. List this case on 29.10.2025.”

27. Moving ahead, in compliance with the above-noted order of this

Court dated 24.09.2025, the State, through the Director-in-Chief,

Health Services, Jharkhand, filed a supplementary affidavit dated

12.03.2026. In paragraph 9 of the said affidavit, it has been explicitly

stated that burn wards are in operation in hospitals throughout the 24

districts of the State of Jharkhand with "adequate logistics." To

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substantiate this claim, a tabular chart was appended as Annexure-I,

purportedly showing the list of district hospitals which have operational

burn units.

28. However, a meticulous perusal of the said Annexure-I reveals

glaring inconsistencies that contradict the State’s own assertions. While

the State claims that burn wards are operational across all 24 districts,

the tabular representation lists only 22 units. Moreover, this internal

inconsistency is further highlighted by the fact that Jamshedpur has

been represented by two different hospitals, appearing at both serial

numbers 8 and 18 of the same table, meaning that even with multiple

facilities in one district, the list still fails to account for the remaining

districts of the State.

29. We find it difficult to reconcile the State’s current claim of

"adequate logistics" with the definitive findings of the Audit, especially

when the latest Annexure-I fails to provide a transparent accounting of

the very units previously flagged by the CAG in its performance audit

report on District Hospital Outcomes in Jharkhand in the year 2021.

Such a "paper-based" compliance mechanism, where infrastructure

exists in budgetary allocations and structural completions but remains

absent in clinical practice, risks rendering the fundamental right to

health under Article 21 illusory.

30. In a welfare State, the constitutional mandate of providing

effective medical care cannot be satisfied by the mere existence of

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buildings if they lack the life-saving machinery and trained manpower

essential for treating specialised trauma such as burn injuries.

31. The gravity of this systemic failure must be viewed through the

prism of the devastating impact that burn injuries have on the human

condition. Burn injury is not merely a clinical trauma; rather, it is a

significant public health crisis in India, which carries the highest

mortality and disability burden in the world. As noted in the study by

Yakupu A. et al. (2022), "The epidemiological characteristic and

trends of burns globally" (BMC Public Health 22: 1596), the 2019

Global Burden of Disease study estimates that India suffers more

than 25,000 deaths and 1.5 million Disability Adjusted Life Years

(DALYs) annually due to burns.

32. The grim reality is further reinforced by the World Health

Organization (WHO) Global Health Estimates (2020), which

indicate that in 2019 alone, more than 23,000 fire-related deaths

were estimated in India. This accounts for approximately 20% of

the global mortality burden. Furthermore, the burden among women

aged 15–49 years in India is three times higher than among men,

highlighting a gendered vulnerability that a welfare State cannot ignore.

33. These statistics are not mere numbers; they represent a persistent

and profound challenge to the realisation of the "Right to Health" and

"Right to Effective Medical Care" guaranteed under Article 21 of the

Constitution of India. It has been time and again held by the Hon’ble

Supreme Court that the right to life does not mean a mere animal

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existence. The Hon’ble court has held in numerous cases that it

encompasses the right to live with human dignity, which in turn

necessitates access to specialized, time-sensitive medical intervention.

In the case of burn trauma/injuries, where every minute is critical

to preventing multi-organ failure and permanent disfigurement,

the absence of functional, district-level burn units renders the

constitutional guarantee of life illusory for most of our citizens.

34. The transformation of the right to life from a mere negative

guarantee against State interference into a positive mandate for well-

being is a hallmark of our constitutional jurisprudence. Since the

landmark intervention in Maneka Gandhi v. Union of India, reported

in AIR 1978 SC 597, the process of elaborating the meaning of "life"

under Article 21 of our Constitution has been relentless.

35. Centrally positioned within this expanding galaxy of rights is the

Right to Health. In Consumer Education and Research Centre v.

Union of India, reported in (1995) 3 SCC 42 and Kirloskar Brothers

Ltd. v. Employees' State Insurance Corporation, reported in (1996)

2 SCC 682, the Hon’ble Supreme Court for the first time accepted that

the right to health is a meaningful and unwavering segment of life. By

reading Articles 39(a), 41, and 43 alongside Article 21, the Hon’ble

Court concluded that health and medical care are basic rights essential

for a life of dignity.

36. The specific duty of the State to provide emergency medical aid

was authoritatively established by the Hon’ble Apex Court in the case

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of Parmanand Katara v. Union of India, reported in (1989) 4 SCC

286, the Hon’ble Court held that securing the health of an injured

person is a paramount obligation, whether the facility is private or

public, and must be undertaken without waiting for legal formalities.

37. This principle finds its most direct application to the present case

in Paschim Banga Khet Mazdoor Samity v. State of West Bengal,

reported in (1996) 4 SCC 37. In that case, the denial of medical aid to

an injured person due to the non-availability of beds was held to be a

violation of Article 21 by the Hon’ble Supreme Court. The Hon’ble

Apex Court categorically asserted that a welfare State cannot resort to a

"lack of financial funds" to bypass its constitutional obligation to

provide primary and emergency health infrastructure.

38. In view of the exhaustive constitutional and statutory framework

discussed hereinabove, it is evident that the "Right to Health" is not a

static concept but a dynamic obligation that evolves with the

availability of specialized medical knowledge and the State's own

policy commitments. The NPPMBI Operational Guidelines,

formulated during the 12th Five-Year Plan, are not merely aspirational

documents, they constitute a "Standard of Care" that the State has

voluntarily undertaken to provide. When the State’s own data (at the

all-India level) admits that burn mortality in India, one death every four

minutes, exceeds that of Malaria and Tuberculosis, the failure to

operationalize even the sanctioned infrastructure in the districts of

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Jharkhand represents a significant gap in the fulfillment of the mandate

under Article 21 of the Constitution.

39. As emphasised by the Hon’ble Supreme Court in the case of

Paschim Banga Khet Mazdoor Samity (supra), the State cannot

plead financial constraints to shirk its primary obligation of providing

emergency medical care. The management of burns is a distinct

medical super-specialty that requires more than just a bed in a general

ward; it requires a sterile ecosystem, specialized logistics, and a

dedicated workforce. In a welfare State, the "Right to Life" includes the

right to a dignified recovery and the prevention of permanent

disfigurement.

40. Consequently, in view of the "seminal public issue" identified in

our order dated 22.07.2025, it is now evident that the existing internal

monitoring mechanisms have been insufficient to bridge the gap

between policy and practice.

41. The "Right to Health" under Article 21 is a positive mandate that

requires the State to provide specialized, time-sensitive medical

infrastructure, particularly for burn trauma, a condition where mortality

and disability are directly linked to the immediacy of specialized care.

42. The continued reliance on general medical facilities, years after

the formulation of the NPPMBI Operational Guidelines, necessitates a

structured judicial intervention to ensure that the constitutional

guarantee of life with dignity is translated into a functional reality.

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43. Accordingly, having regard to the material on record and the

issues noted above, we consider it appropriate to issue certain directions

to ensure that the availability of specialised burn care facilities in the

State is addressed in a time-bound manner, and dispose of the present

petition in the following terms. If any infrastructure has already been

established during the pendency of this litigation, such facilities shall be

appropriately strengthened and made fully functional in accordance

with law, so as to ensure effective medical care consistent with the

mandate of Articles 21 and 47 of the Constitution of India.

44. We therefore direct:

a) The State Government, through the Secretary,

Department of Health, Medical Education and Family

Welfare, shall ensure that dedicated burn units are

made fully functional in all district hospitals and

government medical colleges across the State of

Jharkhand within a period of 120 days from the date

of this judgment, in accordance with applicable

guidelines, including those issued under the National

Programme for Prevention and Management of Burn

Injuries (NPPMBI).

b) The state Government shall further ensure that such

burn units are not merely established in form but are

rendered fully functional, with the adequate

availability of trained medical and paramedical

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personnel, essential equipment, and supporting

infrastructure, in strict adherence to the aforesaid

guidelines.

c) The State Government shall ensure that all designated

burn units are adequately stocked with essential

medicines, consumables and supplies required for the

management of burn injuries, in accordance with

standard treatment protocols and applicable

guidelines, and that uninterrupted availability of the

same is maintained at all times.

d) The State Government shall ensure that burn patients

are treated exclusively in designated burn units

equipped with appropriate isolation facilities and

infection-control measures, and not in general wards,

except, of course, in documented and unavoidable

circumstances.

e) To ensure the efficacy of these units, the State

Government shall take all necessary steps to provide

round-the-clock medical care, including uninterrupted

access to specialist services and emergency treatment

facilities within the said units.

f) Complementary to the infrastructure, the State

Government shall undertake comprehensive training

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and capacity-building measures for doctors, nurses,

and paramedical staff engaged in burn care, in

accordance with applicable protocols, within a period

of 90 days from the date of this judgment.

g) The State Implementation Committee or State

Monitoring Committee, as contemplated under Clause

9.2 of the Operational Guidelines of the NPPMBI,

shall be made operational and functional forthwith.

However, if such a Committee has not yet been

constituted, the State Government shall ensure its

constitution within four weeks from today, strictly in

accordance with the aforesaid Guidelines.

h) The said Committee, headed by the Principal

Secretary (Health), shall function as the State-level

supervisory body to oversee the implementation of the

directions issued herein, including review of

infrastructure, manpower and the operational status of

burn units across the State. The Committee shall meet

at least once every three months to ensure that

deficiencies, if any, are identified and addressed

within the stipulated time frame.

i) The Director-in-Chief, Health Services, Jharkhand,

shall function as the nodal authority for the

coordination and day-to-day implementation of the

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directions issued in this judgment, while the State

Government shall ensure the allocation of adequate

financial and administrative resources for the same.

j) Insofar as the victims of the incident in question are

concerned, it shall be open to them or their legal heirs

to approach the jurisdictional court seized of the

proceedings arising out of Muffasil P.S. Case No.

45/2021 for the grant of compensation, including

interim compensation, under the Victim

Compensation Scheme framed under Section 357-A

of the CRPC, 1973/Section 396 of the Bharatiya

Nagarik Suraksha Sanhita, 2023. However, in the

event that any victims or their legal heirs are unable to

make such an application, the Secretary, District Legal

Services Authority (DLSA), Hazaribagh, shall take

appropriate steps, including with the assistance of

Para Legal Volunteers, to identify such victims and

facilitate the filing of applications.

k) The jurisdictional court shall, upon such application

being made or otherwise, consider the issue of grant

of compensation, including interim compensation, in

accordance with law, as expeditiously as possible and

preferably within a period of three months from the

date of such application.

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l) Upon receipt of any recommendation from the

jurisdictional court, the District Legal Services

Authority (DLSA), Hazaribagh, shall act with

promptitude and, after conducting due enquiry in

accordance with law, take a decision on the claim for

compensation, preferably within a period of one

month from the date of receipt of such

recommendation.

m) The jurisdictional court seized of Muffasil P.S. Case

No. 45/2021 shall endeavour to proceed with the trial

expeditiously and, as far as practicable, ensure that the

trial is concluded at the earliest, in accordance with

law.

45. The Registry of this Court is directed to forthwith communicate

an authenticated copy of this order to: (i) the Principal

Secretary/Secretary, Department of Health, Medical Education and

Family Welfare, Government of Jharkhand; (ii) the Director-in-Chief,

Health Services, Government of Jharkhand; (iii) the Principal District

and Sessions Judge-cum-Chairman, D.L.S.A, Hazaribagh; (iv) the

Secretary, District Legal Services Authority, Hazaribag and

(v) the court having seisin of Muffasil P.S. Case No. 45/2021.

46. Before parting, we place on record our genuine appreciation for

the valuable assistance rendered by the learned Amicus Curiae. The

meticulous research and constructive suggestions provided have been

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instrumental in enabling this Court to address the systemic gaps in the

state's medical infrastructure in the larger public interest.

47. Pending application(s), if any, shall also stand disposed of. No

costs.

48. All concerned must act on an authenticated copy of this judgment

and order.

(M. S. Sonak, C.J.)

(Rajesh Shankar, J.)

Dated: 01.04.2026

A.F.R.

Manoj/Cp.2

Uploaded on 01.04.2026