Justice delayed is justice denied: When Supreme Court issued fresh directions on delay in pronouncement of judgments by High Courts

In a major ruling on how High Courts should deal with chronic delays in delivering judgments, the Supreme Court has repeated and intensified its previous instructions on how such delays should be timely eliminated to bring about timely delivery of the reserved judgment. The Court placed special emphasis on the importance of ensuring that the lack of explanation about delays negatively affects the faith of the people in the justice delivery system, thus it ordered that, in the event that a judgment is not delivered within three months of it being reserved, the Registrar General was to present the matter before the Chief Justice of the High Court to take the necessary action.On 25.08.2025, a bench of Justice Sanjay Karol and Justice Prashant Kumar Mishra in Ravindra Pratap Shahi vs State of U.P. & Ors. The appeals came as a result of highly protracted proceedings before the Allahabad High Court, in which a criminal appeal pending decision in December 2021 was not decided in an unreasonably long time.Background of the case:The appellant, the de-facto complainant, filed the present criminal appeals challenging interim orders of 28.08.2024 and 09.01.2023 passed by the Allahabad High Court in Criminal Appeal No. 939 of 2008, in which the appeal favored by respondent no. 2 had not been heard.The appellant argued that the criminal appeal had been pending since the year 2008, although there were several efforts to have it listed and disposed at an early stage. He said that he had applied to the High Court nine times to have an early hearing, yet no final judgment was delivered.The Division Bench of the High Court eventually decided to leave with the appeal pending judgment on 24.12.2021 after hearing detailed arguments. However, no judgement followed. This inaction was so long that the appellant had to approach the Supreme Court.Proceedings before Supreme Court:The Supreme Court by an order dated 15.04.2025 directed the High Court to determine the appeal in a timely manner, but ideally in less than three months. The Court, however, given that the case was already under consideration of judgment in December 2021, and had not been decided, saw the need to investigate the structural problem of delayed delivery of verdicts.On 27.01.2025, the Supreme Court directed the Registrar General of the Allahabad High Court to submit a report and to bring the issue to the notice of the Chief Justice of the High Court.The report dated 29.01.2025 verified that the judgment was not given within six months, despite the appeal being heard and being reserved on 24.12.2021. Therefore, according to an administrative order dated 07.03.2019, the case was referred to a Regular Bench listing. The case was once more presented to the Chief Justice on 19.12.2022 and scheduled to proceed according to the roster on 09.01.2023, but did not proceed in a meaningful way.Analysis of the Supreme Court:Taking note of these facts, the Supreme Court expressed strong disapproval of the prolonged delay. The Court observed that it was “extremely shocking and surprising” that a judgment was not delivered for almost a year after arguments were concluded.The Bench observed that it was often faced with cases of the same nature and the proceedings could take many months or even years to be decided upon even after being earmarked to be decided upon. The Court also noted that in most High Courts there is no proper mechanism that lets litigants make such delays known to the Chief Justice or the Bench in question.The Court cautioned that such delays would lead litigants to lose confidence in the judicial process, which will be counterproductive to the purposes of justice.“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. 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 Bench relied on the landmark judgment in Anil Rai v. State of Bihar, (2001) 7 SCC 318, where the Supreme Court had addressed the issue of inordinate delays in pronouncement of judgments.The quoted observations read:“9. 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. 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. For the fault of a few, the glorious and glittering name of the judiciary cannot be permitted to be made ugly. It is the policy and purpose of law, to have speedy justice for which efforts are required to be made to come up to the expectation of the society of ensuring speedy, untainted and unpolluted justice.”“10. Under the prevalent circumstances in some of the High Courts, I feel it appropriate to provide some guidelines regarding the pronouncement of judgments which, I am sure, shall be followed by all concerned, being the mandate of this Court…”The Court subsequently reproduced the five special guidelines provided under Anil Rai such as dates of reservation and pronouncement to be recorded, monthly reporting by court officers, intervention by Chief Justice after two to three months and right of parties to request transfer of the case in case judgment is not delivered within six months.The Supreme Court also took serious note of another disturbing practice by certain High Courts of delivering final operative orders without giving the reasoned judgment that accompanies them over a long period.The Court condemned such practice by citing a history of precedents such as the State of Punjab v. Zahira Habibulla H. Sheikh v Jagdev Singh Talwandi. State of Gujarat, Mangat Ram v. State of Haryana, Ajay Singh v. State of Chhattisgarh, and recent cases like the Balaji Baliram Mupade and Ratilal Jhaver bhai Parmar.The Court said that withholding reasoned judgments deprives the aggrieved party of the opportunity to seek further judicial redress, including appellate or revisional remedies.Restating the bindingness of Anil Rai, the Supreme Court provided further instructions on operations to guarantee rigorous adherence:

The Court explained that such directions are supplementary and not in lieu of those established in Anil Rai.In light of the above observations and directions, the Supreme Court disposed of the present appeals. The Court directed that a copy of the judgment be circulated to the Registrar Generals of all High Courts to ensure uniform compliance across the country.CRIMINAL APPEAL NO(S).3700-3701 OF 2025 RAVINDRA PRATAP SHAHI versus STATE OF U.P. & ORS.For Appellant(s): Mr. S. Nagamuthu, Sr. Adv. Mr. Devesh Mohan, Adv. Mr. Kush Chaturvedi, AOR Ms. Prerna Priyadarshini, Adv. Mr. Syed Faraz Alam, Adv. Mr. Atharva Gaur, Adv. Mr. Aayushman Aggarwal, Adv. Ms. Ayesha Choudhary, Adv. For Respondent(s): Ms. Preetika Dwivedi, AOR(Vatsal Chandra is a Delhi-based Advocate practicing before the courts of Delhi NCR.)