Long Delays in High Court Judgment

Source: Supreme Court  

Why in News? 

Recently, Justice Sanjay Karol and Justice Prashant Kumar Mishra were shocked by long delays in High Courts giving judgments and said courts must follow earlier rules (Anil Rai v. State of Bihar (2001)) that allow parties to complain if a verdict isn’t given within six months. 

• The Supreme Court held this in the matter of Ravindra Pratap Shahi v. State Of U.P (2025). 

What was the Background of Ravindra Pratap Shahi v. State Of U.P, (2025) Case? 

• This case stems from a criminal appeal (Criminal Appeal No. 939 of 2008) that has been pending in the Allahabad High Court since 2008.  
• The appellant, Ravindra Pratap Shahi, approached the Supreme Court challenging interim orders dated 28th August 2024 and 9th January 2023, citing prolonged delays in case disposal. 
• Despite the appellant's nine separate attempts to seek early listing and hearing, the High Court failed to deliver any final verdict for seventeen years. 
• The matter took a critical turn when the Division Bench heard extensive arguments and reserved the case for orders on 24th December 2021. However, the promised judgment was never delivered, creating a judicial deadlock. 
• Following administrative protocols, the case was reassigned to a Regular Bench when the original bench failed to deliver judgment within six months.  
• The matter was subsequently listed on 9th January 2023, but when no one appeared for the appellant, it was adjourned to 6th February 2023. Thereafter, multiple hearing dates failed to materialise, leaving the appeal in perpetual limbo. 
• The Supreme Court initially issued administrative directions on 15th April 2025, requesting the High Court to decide the appeal within three months. When this proved ineffective, the apex court directed the Registrar General to submit a detailed report.  
• The report dated 29th January 2025 confirmed all allegations, verifying that the appeal was reserved on 24th December 2021 but no judgment was delivered, representing a complete breakdown of judicial administration and the appellant's constitutional right to timely justice. 

What were the Court’s Observations? 

• The Supreme Court expressed profound shock at the systemic failure of High Courts to deliver timely judgments, describing the situation as "extremely shocking and surprising." The Court observed that judgment delivery delays have become a recurring crisis, with proceedings remaining pending for months or years after hearings conclude across various High Courts. 
• The Court noted with concern the absence of effective mechanisms in most High Courts enabling litigants to approach concerned Benches or Chief Justices regarding judgment delays. This institutional gap forces citizens into helplessness, causing them to lose faith in the judicial process and defeating the fundamental ends of justice. 
• Emphasising the societal implications, the Court warned that in a country where citizens regard judges as second only to God, persistent delays provide legitimate grounds for public concern about judicial efficiency, potentially shaking confidence in the entire judicial system if left unchecked. 
• The Court reiterated the guidelines established in Anil Rai v. State of Bihar (2001), which mandate monthly reporting of reserved judgments, automatic Chief Justice intervention after two months, and parties' rights to seek case transfer if judgments remain undelivered beyond six months. 
• The Court particularly deprecated the practice of pronouncing final orders without reasoned judgments, which are then delayed indefinitely, depriving aggrieved parties of opportunities to seek further judicial redressal and violating natural justice principles. 
• To strengthen enforcement, the Court issued supplementary directions requiring Registrar Generals to furnish monthly lists of undelivered judgments to Chief Justices for three months. If judgments remain undelivered beyond three months, Chief Justices must direct concerned Benches to pronounce orders within two weeks, failing which cases must be reassigned to different benches. 
• The Court emphasised these directions as mandatory compliance requirements, ordering circulation to all High Court Registrar Generals to establish uniform implementation standards nationwide. 

What were the Guidelines of Anil Rai v. State of Bihar (2001) ? 

• Recording and Reporting Requirements 
  • High Courts must record reservation and pronouncement dates on the first page of judgments. Court Officers must furnish monthly lists of cases where reserved judgments remain unpronounced to Chief Justices for administrative monitoring. 
• Progressive Timeline Interventions 
  • After two months of delay, Chief Justices must alert concerned Benches about pending matters. Within three months, parties can file applications for early judgment, which must be listed within two days before the concerned Bench. 
• Six-Month Transfer Provision 
  • If judgment is not pronounced within six months of reservation, parties can approach the Chief Justice seeking case withdrawal and reassignment to another Bench for fresh arguments, with Chief Justice having discretion to grant such prayers. 
• Judicial Accountability Principle 
  • The Court established that judgment delivery is integral to the justice dispensation system and must occur without delay, as prolonged delays shake public confidence in judicial efficiency and defeat the fundamental ends of justice. 

Related Cases on Delayed Judgment Delivery  

• Pila Pahan @ Peela Pahan and Ors. v. The State of Jharkhand and Anr. (2025) 
  • Four convicts belonging to Scheduled Tribes/Other Backward Classes communities approached the Supreme Court alleging that their criminal appeals, though reserved by the Jharkhand High Court in 2022, remained undecided for 2-3 years.  
  • The convicts, sentenced to life imprisonment for murder and rape charges, argued that the delay violated their fundamental right to life and personal liberty under Article 21, which includes the right to speedy trial. One convict had been in jail for over 16 years while others served 11-14 years, yet they couldn't apply for remission since judgments remained reserved.  
  • The Supreme Court, expressing that such delays were "very disturbing," directed all High Court Registrar Generals to submit reports on cases where judgments were reserved on or before 31st January 2025, but remained unpronounced, categorising them into criminal and civil matters with bench specifications.  
• Balaji Baliram Mupade v. State of Maharashtra (2020)  
  • The Supreme Court addressed the problematic practice of High Courts pronouncing operative portions of orders without providing reasoned judgments, which were then delayed for extended periods.  
  • In this case, the Bombay High Court's Aurangabad bench pronounced the operative order on 21st January, 2020, but published the detailed reasons only on 9th October, 2020, creating a nine-month gap.  
  • The Court observed that judicial discipline requires promptness in judgment delivery, and delays compound when results are known but reasons are withheld, depriving aggrieved parties of opportunities to seek further judicial redressal. 
  • The bench comprising Justices Sanjay Kishan Kaul and Hrishikesh Roy emphasised that such practices violate Article 21 of the Constitution and directed circulation of their order to all High Courts as a reminder against such delays.  
• Umesh Rai @ Gora Rai v. Union of India (2023)  
  • This case involved a convict who had been in custody for 16 years, 9 months, and 18 days, seeking bail after the Allahabad High Court failed to pronounce judgment reserved in August 2022 for his criminal appeal filed in 2014. 
  • When the Supreme Court sought a status report, the Assistant Registrar revealed that the matter was re-listed before the same bench that had originally reserved it, contrary to established judicial protocols.  
  • The Supreme Court, comprising Justices Sanjay Kishan Kaul and Ahsanuddin Amanullah, expressed strong disapproval of reassigning the matter to the same bench, stating this was "completely unsatisfactory." 
  • Following the Anil Rai precedent that mandates case transfer to different benches after six months of non-delivery, the Court directed the Chief Justice to assign the matter to another bench and granted interim bail to the appellant, noting they had "little option" given the prolonged custody period.