In the Matter of Suo Moto Public Interest Litigation Vs State of Chhattisgarh

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2026:CGHC:24280-DB NAFR

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Digitally signed ALOKSHARMA by ALOKSHARMADate:2026.06.18 18:30:37 +0530

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HIGH COURT OF CHHATTISGARH AT BILASPUR

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WPPIL No. 90 of 2025

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1 - In The Matter Of Suo Moto Public Interest Litigation Of The Pathetic Condition Of Gram Panchayat Muktidham At Rahngi Lacking In Basic Amenities And Also There Is A Solid And Wet Waste Management Shed Adjacent To Funeral Place Of Muktidham, Which Is Highly Inappropriate.

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... Petitioner(s)

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versus

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1 - State Of Chhattisgarh Through Chief Secretary, Mahanadi Bhawan Atal Nagar, Nawa Raipur, Chhattisgarh

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2 - Secretary Public Works Department, Mahanadi Bhawan, Atal Nagar Nawa Raipur, Chhattisgarh.

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3 - Secretary Department Of Energy, C.S.P.D.C.L. Mahanadi Bhawan, Atal Nagar Nawa Raipur, Chhattisgarh.

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4 - Collector Bilaspur, District- Bilaspur, Chhattisgarh.

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5 - Sub Divisional Officer Bilha, District- Bilaspur, Chhattisgarh.

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6 - Chief Executive Officer Janpad Panchayat Bilha, District- Bilaspur, Chhattisgarh.

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7 - Sarpanch Gram Panchayat Rahngi Tahsil Bilha, District- Bilaspur Chhattisgarh.

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8 - Secretay Govt. Of Chhattisgarh Panchayat And Social Welfare Department, Mahanadi Bhawan Atal Nagar Nawa Raipur (C.G.)

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	... Respondent(s)
For State	: Mr. Shashank Thakur, Additional Advocate
	General.
For Respondent No. 3	: Mr. Mayank Chandrakar, Advocate.
For Respondent No. 9	: Mr. Anadi Sharma, Advocate.

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Hon'ble Shri Ramesh Sinha, Chief Justice Hon'ble Shri Ravindra Kumar Agrawal, Judge

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Order on Board

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Per Ramesh Sinha, Chief Justice 17/06/2026

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1 . This is an office reference.

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The present suo motu Public Interest Litigation was registered pursuant to the order dated 29.09.2025 passed by this Court after taking cognizance of the pathetic condition of the Muktidham situated at Gram Panchayat Rahangi, Tahsil Bilha, District Bilaspur. During a visit to the said Muktidham, Hon'ble the Chief Justice noticed the absence of basic civic amenities and infrastructure necessary for ensuring a dignified cremation and funeral process. The Muktidham was found to be lacking in essential facilities such as a proper boundary wall, approach road, drinking water facility, electricity, toilets, waiting shed, seating arrangements and adequate sanitation. The existence of a solid and wet waste management shed adjacent to the cremation ground was also noticed, which was found to be wholly inappropriate.

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Considering the significance of the issue, this Court observed that the right to life guaranteed under Article 21 of the Constitution of India includes the right to a dignified death and dignified cremation. It was further observed that a cremation ground is a public utility of immense social importance and the State is under a constitutional obligation to ensure that such places are maintained in a clean, safe and dignified condition.

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Accordingly, by order dated 29.09.2025, this Court issued

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comprehensive directions to the State Government and the concerned authorities for immediate improvement of the Muktidham in question and for evolving a mechanism to ensure maintenance of cremation grounds throughout the State. Directions were issued for cleanliness drives, repair and construction of necessary infrastructure, provision of drinking water and electricity, construction of waiting sheds and toilets, deployment of sanitation workers, appointment of nodal officers and formulation of standard guidelines for maintenance of Muktidhams.

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Pursuant to the said directions, personal affidavits were filed by the Chief Secretary, Government of Chhattisgarh, the Principal Secretary, Panchayat and Rural Development Department and the Collector, Bilaspur. The affidavits disclosed that detailed guidelines had been issued by the Panchayat and Rural Development Department on 06.10.2025 and by the Urban Administration and Development Department on 08.10.2025 for maintenance and upgradation of Muktidhams in rural and urban areas. The authorities further informed this Court that various measures had been undertaken for providing basic amenities and improving the condition of cremation grounds throughout the State.

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In compliance with the orders passed by this Court, reports along with photographs were submitted by the Collectors of all districts of the State. The reports indicated that cleanliness drives had been undertaken, boundary walls and fencing had been constructed or proposed, damaged sheds and platforms had been repaired, drinking water and lighting facilities had been installed, toilets had been provided

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and mechanisms had been put in place for regular maintenance and monitoring of Muktidhams.

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Subsequently, this Court also took cognizance of a newspaper report regarding incomplete construction and beautification work at the Sirgitti Muktidham, Bilaspur. In that regard, the Commissioner, Municipal Corporation, Bilaspur was directed to file a personal affidavit explaining the status of the work.

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In compliance thereof, the Commissioner, Municipal Corporation, Bilaspur filed affidavits from time to time. Lastly, in compliance with the order dated 28.01.2026, a further personal affidavit dated 16.03.2026 was filed by the Commissioner, Municipal Corporation, Bilaspur. The affidavit discloses that the work of beautification and infrastructural development of the Muktidham is in progress; the construction of the crematorium is substantially complete and only finishing work remains; construction of the waiting hall is underway; and regular maintenance of cleanliness, sanitation and other basic facilities is being ensured by the Municipal Corporation.

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The affidavit further contains a categorical assurance that the remaining works shall be completed within the stipulated timeline and that the Municipal Corporation shall continue to maintain the Muktidham in a dignified, functional and sanitary condition irrespective of the completion of the remaining civil works.

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The relevant observations made in the affidavit are that the Municipal Corporation remains fully committed to ensuring completion of all remaining work within the stipulated period and recognizes the

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sensitivity and public importance of cremation grounds. It has undertaken before this Court to maintain the Muktidham in a dignified, functional and sanitary condition on a continuous basis.

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This Court has carefully considered the affidavits filed by the State authorities, the reports submitted by the Collectors of all districts and the affidavits filed by the Commissioner, Municipal Corporation, Bilaspur. The material placed on record demonstrates that the deficiencies which led to initiation of the present proceedings have been substantially addressed. It is also evident that the State Government has utilized the opportunity provided by these proceedings to formulate a comprehensive framework for maintenance, monitoring and development of Muktidhams and cremation grounds across the State. 12. The objective of the present suo motu Public Interest Litigation was not only to address the deficiencies existing at a particular Muktidham but also to ensure that the citizens of the State are able to perform the last rites of their loved ones in an environment consistent with human dignity and constitutional values. The action taken by the State Government and the local authorities pursuant to the orders of this Court indicates a sincere effort in that direction.

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In view of the affidavits filed and the assurances extended by the respondent authorities, particularly the affidavit dated 16.03.2026 filed by the Commissioner, Municipal Corporation, Bilaspur, this Court is of the considered opinion that the purpose for which the present proceedings were initiated stands substantially achieved and no further monitoring is required at this stage.

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Accordingly, while disposing of the present Public Interest Litigation, this Court records its appreciation for the efforts undertaken by the State Government, the District Administrations, Municipal Corporations, Municipal Councils, Nagar Panchayats, Gram Panchayats and all officers concerned in addressing the issues highlighted during the course of these proceedings.

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At the same time, this Court expresses its hope and trust that the State Government, the Panchayat and Rural Development Department, the Urban Administration and Development Department, the Forest Department, wherever concerned, the District Collectors, Municipal Corporations, Municipal Councils, Nagar Panchayats, Gram Panchayats and all other competent authorities shall continue to ensure strict compliance with the guidelines issued on 06.10.2025 and 08.10.2025 as well as the assurances furnished before this Court.

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This Court further hopes and trusts that adequate and effective steps shall continuously be taken for maintaining cleanliness, sanitation, drinking water facilities, electricity, toilets, boundary walls, approach roads, waiting sheds, seating arrangements and all other essential facilities at the Muktidhams and cremation grounds throughout the State, so that the dignity of the deceased and the sentiments of their family members are duly respected. 17. It is made clear that maintenance of cremation grounds is a continuing obligation and any lapse in this regard would amount to failure to discharge the constitutional responsibilities cast upon the authorities concerned. Therefore, if any serious laxity, negligence,

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inaction or non-compliance with the assurances recorded herein or the guidelines issued by the State Government is brought to the notice of this Court in future, it shall be open to this Court to re-open the matter and pass such further orders as may be deemed necessary in accordance with law.

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With the aforesaid observations, expectations and liberty reserved as above, the present Public Interest Litigation stands disposed of.

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Sd/- Sd/-

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(Ravindra Kumar Agrawal) (Ramesh Sinha) Judge Chief Justice

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Alok

In the Matter of Suo Moto Public Interest Litigation v. State of Chhattisgarh

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In the Matter of Suo Moto Public Interest Litigation v. State of Chhattisgarh

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