Supreme Court | Directions to All High Courts on Timely Pronouncement of Reserved Judgments | If Not Delivered Within Three Months, Registrar General Must Place Matter Before Chief Justice
Kiran Raj
The Supreme Court of India Division Bench of Justice Sanjay Karol and Justice Prashant Kumar Mishra has directed that High Courts must adhere to a structured mechanism ensuring the timely pronouncement of judgments once matters are reserved. The Court reiterated earlier guidelines mandating a maximum period for delivery, requiring Registrar Generals of High Courts to monitor pending reserved matters and place them before the Chief Justice if not pronounced within prescribed timeframes. The Bench further ordered that matters be reassigned to alternate Benches in cases where judgments remain pending beyond stipulated limits.
The appeals before the Supreme Court arose from interim orders of the High Court of Judicature at Allahabad in Criminal Appeal No.939 of 2008, wherein proceedings were repeatedly adjourned without final pronouncement. The appeal had been filed by one of the respondents as far back as 2008, and despite multiple efforts for early hearing and disposal, no judgment was delivered by the High Court over several years.
According to the appellant, who was the de facto complainant, nine separate applications were filed before the High Court seeking early listing and disposal of the criminal appeal. After protracted delays, arguments were finally heard in full by the Division Bench of the High Court, and the matter was reserved for judgment on 24 December 2021. However, no pronouncement followed.
On 27 January 2025, the Supreme Court, upon hearing submissions, directed the Registrar General of the High Court of Judicature at Allahabad to verify the averments regarding the prolonged non-delivery of judgment and to submit a report to the Court. The Registrar General’s report dated 29 January 2025 confirmed that the matter had indeed been reserved for judgment since 24 December 2021 but, in view of the administrative order of the Chief Justice dated 7 March 2019, had to be relisted before the Regular Bench after six months lapsed without delivery.
The matter was subsequently placed before the Chief Justice again on 19 December 2022, who directed that the case be listed as per the roster. On 9 January 2023, however, when the case was called, no one appeared for the appellant, and the matter was adjourned to 6 February 2023. Thereafter, the hearings failed to materialise, leaving the appeal undetermined.
The appellant contended before the Supreme Court that such inordinate delays and the absence of a mechanism to enforce timely delivery of reserved judgments resulted in denial of justice and loss of faith in judicial processes. The Registrar General’s report lent support to these contentions by acknowledging that despite full arguments having been heard and the matter reserved for orders, the final decision remained pending indefinitely.
In light of these facts, the Supreme Court considered whether fresh directions were necessary to ensure that litigants are not left remediless in situations where High Courts delay pronouncing judgments after reserving them.
The Court recorded: “It is extremely shocking and surprising that the judgment was not delivered for almost a year from the date when the appeal was heard. This Court is repeatedly confronted with similar matters wherein proceedings are kept pending in the High Court for more than three months, in some cases for more than six months or years wherein judgments are not delivered after hearing the matter.”
The Bench observed further: “In most of the High Courts, there is no mechanism where the litigant can approach the concerned Bench or the Chief Justice bringing to its notice the delay in delivery of judgment. In such situation, the litigant loses his faith in the judicial process defeating the ends of justice.”
The Court referred to its earlier decision in Anil Rai vs. State of Bihar (2001) 7 SCC 318, in which comprehensive guidelines had been issued regarding the pronouncement of judgments: “It is true, that for the High Courts, no period for pronouncement of judgment is contemplated either under the Civil Procedure Code or the Criminal Procedure Code, but as the pronouncement of the judgment is a part of the justice dispensation system, it has to be without delay. In a country like ours where people consider the Judges only second to God, efforts be made to strengthen that belief of the common man.”
The judgment continued: “Delay in disposal of the cases facilitates the people to raise eyebrows, sometimes genuinely which, if not checked, may shake the confidence of the people in the judicial system. A time has come when the judiciary itself has to assert for preserving its stature, respect and regards for the attainment of the rule of law.”
The Court cited in extenso the guidelines from Anil Rai, noting that Chief Justices of High Courts were expected to ensure monthly reporting of reserved judgments, circulation of cases where orders were pending beyond six weeks, and mandatory reassignment if no judgment was delivered within six months.
The Court further remarked: “Some High Courts have adopted practice of pronouncing the final order without reasoned judgment, which is not delivered for substantial length of time depriving the aggrieved party of the opportunity to seek further judicial redressal.”
Reference was made to earlier decisions, including State of Punjab vs. Jagdev Singh Talwandi (1984) 1 SCC 596, Zahira Habibulla H. Sheikh vs. State of Gujarat (2004) 4 SCC 158, Mangat Ram vs. State of Haryana (2008) 7 SCC 96, and Ajay Singh vs. State of Chhattisgarh (2017) 3 SCC 330, wherein similar concerns had been addressed. The Bench noted that subsequent cases, such as Balaji Baliram Mupade vs. State of Maharashtra (2021) 12 SCC 603 and Ratilal Jhaverbhai Parmar vs. State of Gujarat (2024 INSC 801), had also reiterated these principles.
Summarising, the Court stated: “The directions have already been issued by this Court in Anil Rai (supra). Therefore, what is required today is adherence to the principles laid down by this Court in Anil Rai (supra).”
The Supreme Court issued clear directions requiring strict compliance with time-bound pronouncement of reserved judgments. It ordered: “We reiterate the directions and direct the Registrar General of each High Court to furnish to the Chief Justice of the High Court a list of cases where the judgment reserved is not pronounced within the remaining period of that month and keep on repeating the same for three months. If the judgment is not delivered within three months, the Registrar General shall place the matters before the Chief Justice for orders and the Chief Justice shall bring it to the notice of the concerned Bench for pronouncing the order within two weeks thereafter, failing which the matter be assigned to another Bench.”
The Bench clarified that these directions were “in addition to the guidelines/directions issued by this Court in Anil Rai (supra).”
Concluding, the Court stated: “The present Appeals stand disposed of with the above observations and directions. Let a copy of this judgment be circulated to the Registrar Generals of all the High Courts for compliance.”
Case Title: Ravindra Pratap Shahi v. State of U.P. & Ors.
Neutral Citation: 2025 INSC 1039
Case Number: Criminal Appeal Nos. 3700-3701 of 2025 (Arising out of SLP (Crl.) Nos. 4509-4510 of 2025)
Bench: Justice Sanjay Karol, Justice Prashant Kumar Mishra
