The Punjab and Haryana High Court, while addressing the serious issue of illegal activities being conducted under the cover of spa and massage centres, has directed the Punjab Government to draft and implement guidelines or a policy to regulate such establishments within the State.
In a judgment dated April 7, 2025, Justice Kuldeep Tiwari observed that many spa and massage centres in Punjab are allegedly being used as fronts for prostitution and human trafficking.
“From the FIR figures (supra), which appertain only to one Commissionerate, this Court prima facie believes such kind of rackets to be operating in the entire State,”
– Justice Kuldeep Tiwari, Punjab & Haryana High Court
This observation was made while hearing CWP-28707-2024, a writ petition filed by several individuals including Shabnam Khatun and others, who own beauty parlours and spa centres in Jalandhar. They approached the Court seeking relief from alleged harassment by police officials, claiming interference in the lawful functioning of their businesses.
In response, the Punjab Government filed a detailed reply dated March 26, 2025, highlighting that several First Information Reports (FIRs) had been lodged within the district of Jalandhar, exposing the operation of prostitution rackets disguised as legitimate spa services.
The FIRs included:
- FIR No. 124 dated 24.06.2022 – Sections 3, 4, 5 of Immoral Traffic (Prevention) Act, PS Division 7
- FIR No. 65 dated 26.04.2023 – Sections 3, 4, 5 of the same Act, PS Division 7
- FIR No. 136 dated 17.09.2023 – Same provisions, PS Division 7
- FIR No. 44 dated 21.04.2024 – Same provisions, PS Division 7
- FIR No. 93 dated 14.05.2024 – Same provisions, PS Division 6
- FIR No. 78 and 79 dated 22.04.2024 – Sections 3, 4, 5, 5B, 5C of the Act, PS Division 6
“The reply dated 26.03.2025… reveals that some miscreants, under the garb of running spa and massage centres, have been running prostitution racket and are involved in immoral/human trafficking.”
– Punjab Government Reply in CWP-28707-2024
Interestingly, the Court noted that even two petitioners in the case—Petitioner Nos. 3 and 7—were themselves named in FIR No. 78 and FIR No. 79 respectively.
Even though the petitioners’ counsel informed the Court that they no longer wished to pursue the writ due to resolution of their grievance, the Court took suo motu cognizance of the larger issue concerning women’s safety and exploitation.
“Taking into account the gravity of the issue involved as well as the welfare of the women working in the spa and massage centres, this Court deems it appropriate to direct the State of Punjab to consider this writ petition as a representation…”
– Justice Kuldeep Tiwari
The High Court has now instructed the Punjab Government to frame a policy or guidelines to regulate the operation of spa and massage centres across the State. This exercise must be completed within three months, and the government is required to submit a status report post compliance.
The Court also cited a previous judgment in CRM-M-36358-2023 which dealt with a similar issue in the Union Territory of Chandigarh. In that case, the Court had urged local authorities to adopt a model similar to the Delhi Government’s guidelines for spa/massage centres. Haryana has already implemented similar regulations.
“There would be no harm if the authorities may think about the similar guidelines (GNCT of Delhi's guideline on operation of Spa/massage centres) for the City Beautiful.”
– Punjab & Haryana HC in Nagaraj T @ Charles v. State of U.T. Chandigarh
This precedent further reinforced the need for uniform and effective regulation to prevent exploitation, ensure women’s safety, and preserve lawful business operations.
Although the main petition was not pressed by the petitioners during the hearing, the Court still disposed of the matter with a strong directive to the State.
“This menace can only be curbed through framing of apt guidelines/policy regulating operation of the spa and massage centres.”
– Justice Kuldeep Tiwari
The judgment was officially recorded and reportable, marking a crucial judicial push towards regulating and sanitizing the operations of spa and massage centres in Punjab.
Mr. Deepak Singh Saini, Advocate with Ms. Parul Saini, Advocate for the petitioners.
Mr. Pardeep Bajaj, D.A.G., Punjab.
Title: SABNAM KHATUN AND ORS V. STATE OF PUNJAB AND ORS
