The Supreme Court expressed concern over delays in pronouncing reserved judgments and directed Registrar Generals of all High Courts to submit detailed reports on cases where such judgments were reserved on or before January 31, 2025, but remain pending. The direction came in a matter filed by four life convicts, where the Court noted that such delays raise serious concerns under Article 21 of the Constitution.
The petition was filed by four convicts currently lodged in Birsa Munda Central Jail, Hotwar, Ranchi. They had challenged their convictions before the Jharkhand High Court in Ranchi. Despite the criminal appeals being heard and judgments reserved back in 2022, the High Court had yet to pronounce verdicts in their cases. Three petitioners were convicted for murder and one for rape, with one convict serving over 16 years of imprisonment and the others having spent between 11 to 14 years in custody.
The petition emphasised that such prolonged silence from the court violates their fundamental right to a speedy trial, a recognised facet of Article 21. They argued that as the right to appeal is an extension of the right to trial, delays in appellate judgments amount to a constitutional infringement.
Advocate Fauzia Shakil, appearing for the petitioners, informed the Court that although the Jharkhand High Court had recently expedited the disposal of several criminal appeals after notice was issued in this writ petition, the appeals filed by the petitioners were still pending final judgment. She also pointed out that two of these matters were listed for judgment on the very date of the Supreme Court hearing.
The petition further cited precedents such as Hussainara Khatoon v. Home Secretary, Bihar, and Akhtari Bi v. State of Madhya Pradesh, underscoring that the right to a speedy trial extends to appeals. It also referenced Anil Rai v. State of Bihar, where the Apex Court had earlier laid down certain guidelines for the timely delivery of reserved judgments.
Additionally, the petitioners highlighted their multiple attempts to seek intervention by submitting representations to the Chief Justice of India, the Chief Justice of the Jharkhand High Court, and other legal authorities. However, they received no response, prompting them to seek relief from the Supreme Court.
The Bench comprising Justice Surya Kant and Justice K.V. Viswanathan (earlier reported as Justice NK Singh, corrected here) took serious note of the issue and termed the delay in pronouncing reserved judgments as “very disturbing.”
The Court orally remarked, “We will definitely like to lay down some mandatory guidelines. It can't be allowed to happen like this.” While recognising the steps taken by the High Court in disposing of other matters, the Supreme Court emphasised the need for a systemic response to prevent such delays from becoming the norm.
Importantly, the Court relied upon a news report that highlighted the Jharkhand High Court’s disposal of 75 criminal appeals in a single week after the Supreme Court had issued notice in this case. The bench directed the Registrar General of the High Court to furnish a list of these 75 appeals, specifying the date on which each judgment was reserved and when it was pronounced.
The Court reiterated its earlier concerns expressed in Anil Rai and HPA International v. Bhagwandas Fateh Chand Daswani, where it had decried the habit of reserving judgments for indefinite durations without pronouncement.
In view of the seriousness of the issue, the Top Court directed the Registrar Generals of all High Courts to submit status reports detailing all cases, civil and criminal, where judgments were reserved on or before January 31, 2025, but have yet to be pronounced. The data must also distinguish whether the matters were heard by single or division benches. Additionally, the Court called upon the Jharkhand High Court to disclose the details of the 75 criminal appeals recently disposed of, including dates of reservation and pronouncement, to ensure transparency.
The matter will now proceed with the Court monitoring the response of the High Courts and possibly laying down binding procedural safeguards to uphold the right to timely justice under Article 21.
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