DATE: 25/08/2025
COURT: Supreme Court of India
BENCH: Justice Sanjay Karol and Justice
Prashant Kumar Mishra
FACTS:
By an order dated April 15, 2025, the
Supreme Court directed the High Court to dispose of the pending criminal appeal
at the earliest, preferably within a period of three months. The appeal in
question had earlier been reserved for judgment on December 24, 2021. However,
despite the lapse of considerable time, no judgment was delivered. When the
matter came up before the Supreme Court on January 27, 2025, the Bench
expressed its concern and directed the Registrar General of the High Court to
immediately place the issue before the Chief Justice.
Pursuant to these directions, the Registrar
General submitted a report indicating that, since the judgment was not
pronounced within six months of being reserved, the matter was dealt with in
accordance with the administrative order of the Chief Justice. Under this
order, cases in which judgments were delayed beyond the prescribed time were to
be placed before a Regular Bench as per the roster. Accordingly, the appeal was
placed before the Chief Justice on December 19, 2022, who directed that it be
listed before the appropriate Bench on January 9, 2023.
On the date so fixed, however, no one
appeared on behalf of the appellant. Consequently, the appeal was adjourned for
hearing on February 6, 2023. Thereafter, on several subsequent occasions, the
hearing could not take place and the matter remained pending without effective
progress.
ISSUES:
The central issue before the Supreme Court
was the inordinate delay in the pronouncement of judgment in Criminal Appeal
No. 939 of 2008 pending before the Allahabad High Court. Although the appeal
had been heard and reserved for judgment on 24.12.2021, no verdict was
delivered. This raised serious concerns about denial of timely justice, the
lack of an effective mechanism in High Courts to deal with delayed
pronouncements, and whether remedial directions were required from the Supreme
Court to address such systemic lapses.
JUDGEMENT WITH REASONING:
The Supreme Court expressed strong
disapproval over the delay, terming it “shocking and surprising” that judgments
were not delivered for long periods despite being reserved. The Court
reiterated and reinforced the guidelines earlier laid down in Anil Rai v. State
of Bihar (2001) 7 SCC 318, while issuing further directions. Specifically, the
Court directed that Registrar Generals of all High Courts must submit monthly
reports to the Chief Justice about cases where judgments remain pending after
being reserved, and if the delay exceeds three months, the Chief Justice must
ensure the concerned Bench pronounces judgment within two weeks or reassign the
case to another Bench. The appeals were accordingly disposed of with these
directions.
The Court’s reasoning was rooted in the
constitutional principle of speedy justice, which is integral to the rule of
law and the faith of the public in the judiciary. The Bench observed that
delays in pronouncing judgments after arguments have been concluded erode the
confidence of litigants, defeat the very purpose of adjudication, and result in
grave injustice. The Court cited earlier precedents, including Anil Rai v.
State of Bihar, State of Punjab v. Jagdev Singh Talwandi, Zahira Habibulla H.
Sheikh v. State of Gujarat, and other recent rulings, which had repeatedly
cautioned against the practice of indefinite delays. The Court emphasized that
while no statutory time-limit is prescribed in procedural law for pronouncing
judgments, judicial discipline and the constitutional obligation to dispense
timely justice make it imperative that judgments be delivered without
unreasonable delay. It highlighted that even the perception of delay damages
the institution’s credibility, as litigants are left without remedies and
deprived of their right to appeal in higher forums. The reiteration of the Anil
Rai guidelines, coupled with additional reporting obligations, was thus deemed
necessary to ensure accountability, transparency, and uniformity across High
Courts.
ANALYSIS:
The case highlights a systemic problem in
the judicial process, long delays in the pronouncement of judgments despite
arguments being concluded. The facts reveal that Criminal Appeal No. 939 of
2008 was reserved for judgment as far back as December 2021, but no verdict was
delivered, forcing the matter to reach the Supreme Court. This lapse not only
prolonged the uncertainty for the parties involved but also exposed gaps in the
administrative mechanism of High Courts to monitor and address delayed
pronouncements. The Supreme Court identified the central issue as the denial of
timely justice and the absence of accountability, which directly undermines
litigants’ faith in the judicial system.
In its decision, the Supreme Court strongly
criticized such practices and reaffirmed the binding nature of its earlier
directions in Anil Rai v. State of Bihar (2001), while strengthening them with
additional safeguards. By mandating monthly reporting by Registrar Generals and
requiring Chief Justices to intervene when delays extend beyond three months,
the Court sought to ensure greater transparency and accountability in the
functioning of High Courts. The judgment underscores the constitutional mandate
of speedy justice as a cornerstone of the rule of law and emphasizes that
judicial delay not only defeats the purpose of adjudication but also erodes
public confidence in the institution. This case, therefore, represents both a
corrective step in an individual appeal and a wider institutional directive
aimed at restoring faith in the justice delivery system.
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