Case Summary: Ravindra Pratap Shahi v. State of U.P. & Ors. (2025) | Directions to High Courts on Reserved Judgments

The Supreme Court of India addressed a pressing issue in this case that has repeatedly plagued the judicial system: inordinate delays in pronouncing judgments after hearings are concluded. The matter stemmed from a criminal appeal that had been pending before the Allahabad High Court since 2008 and, despite being heard and reserved for judgment in December 2021, remained undecided for years. This compelled the appellant to approach the Supreme Court seeking directions to ensure the timely disposal of cases and accountability within the High Courts.

This decision is a significant reiteration and reinforcement of earlier directions laid down in Anil Rai v. State of Bihar (2001) 7 SCC 318, along with subsequent rulings where the Supreme Court emphasised that justice delayed is justice denied. By prescribing a three-month outer limit for the delivery of reserved judgments, the Court attempted to revive faith in the justice delivery system and bring certainty to litigants awaiting finality.

Case Title: Ravindra Pratap Shahi v. State of Uttar Pradesh & Ors.

Court: Supreme Court of India

Citation: Arising out of SLP (Crl.) Nos. 4509–4510 of 2025

Bench: Justice Sanjay Karol and Justice Prashant Kumar Mishra

Date of Judgment: 25 August 2025

Facts of the Case

Parties Involved

Appellant: Ravindra Pratap Shahi, the de-facto complainant.

Respondents: State of Uttar Pradesh and others, including the accused in the original criminal matter.

Case Background

• The criminal appeal had been pending before the Allahabad High Court since 2008.
• The appellant repeatedly approached the High Court—at least nine times—requesting early listing, hearing, and disposal.
• Eventually, the Division Bench heard arguments at length and reserved the matter for judgment on 24 December 2021.

Delay in Pronouncement

• Despite reservation, no judgment was delivered for over a year.
• The Chief Justice of the Allahabad High Court, in accordance with an administrative order dated 07 March 2019, directed that cases where judgments were not delivered within six months would be listed before a Regular Bench.
• On 19 December 2022, the matter was again placed before the Chief Justice and listed on 9 January 2023, but no effective hearing took place as the appellant was absent. The case continued to linger without final disposal.

Supreme Court Intervention

• On 15 April 2025, the Supreme Court noted the alarming delay and directed the High Court to decide the matter within three months.
• On 27 January 2025, the Supreme Court further directed the Registrar General of the High Court to report on the correctness of the averments regarding delay.
• The Registrar General’s report confirmed that the appeal was indeed reserved in December 2021 but remained undecided.
• This sequence of events highlighted the systemic problem of non-delivery of judgments despite completion of arguments.

Issues

• Whether such prolonged delay in pronouncement of judgment after conclusion of hearing violates the principles of justice delivery and litigants’ rights?
• What mechanisms and guidelines should be put in place to ensure accountability of High Courts in delivering reserved judgments within a reasonable time?
• Whether the Supreme Court should prescribe a strict time limit for the delivery of judgments post-hearing and provide remedies when delays occur?

Arguments

Appellant’s Submissions

• The appellant contended that the delay of more than three years after reserving the judgment was grossly unjust and arbitrary, causing prejudice and denial of justice.
• Repeated representations for early listing yielded no result, thereby eroding faith in the judicial system.
• It was argued that High Courts should be bound by stricter procedural accountability, in line with the constitutional right to a fair and speedy trial under Article 21.

Respondents’ Submissions

• The State and other respondents highlighted that the matter had been relisted and adjourned due to the non-appearance of counsel, implying that procedural difficulties contributed to the delay.
• However, there was no substantial justification for the prolonged delay post-reservation of judgment.

Supreme Court’s Observations

1. Shocking Nature of Delay

The Bench (Justices Sanjay Karol and Prashant Kumar Mishra) termed the non-delivery of judgment for over a year after arguments were concluded as “extremely shocking and surprising”.

The Court observed that such delays were not isolated but part of a recurring trend in many High Courts where matters remain pending for months or years even after hearings conclude.

2. Impact on Faith in the Judiciary

The Court emphasised that litigants lose faith when courts do not pronounce judgments within a reasonable time, thereby defeating the ends of justice.

Referring to the status of judges as being held in “God-like” reverence by the public, the Court warned that delay in justice delivery tarnishes the glorious reputation of the judiciary and shakes public confidence.

3. Reference to Anil Rai v. State of Bihar (2001)

The Court quoted extensively from Anil Rai (paras 9-10) which had earlier laid down guidelines for timely pronouncement:

• Pronouncement within two months ideally.
• If delayed beyond three months, litigants can move applications for early judgment.
• If not delivered within six months, the matter can be withdrawn and assigned to another Bench.

4. Other Precedents

The Court referred to:

• State of Punjab v. Jagdev Singh Talwandi (1984) 1 SCC 596
• Zahira Habibulla Sheikh v. State of Gujarat (2004) 4 SCC 158
• Mangat Ram v. State of Haryana (2008) 7 SCC 96
• Ajay Singh v. State of Chhattisgarh (2017) 3 SCC 330
• Balaji Baliram Mupade v. State of Maharashtra (2021) 12 SCC 603
• Ratilal Jhaverbhai Parmar v. State of Gujarat (2024 INSC 801)
• K. Madan Mohan Rao v. Bheemrao Baswanthrao Patil (2022 INSC 1025)

All of these reiterated the imperative of timely judgments.

5. Need for Compliance and Enforcement

The Court held that while guidelines exist, what is urgently required is strict adherence. The lack of effective enforcement mechanisms is the root cause of such recurring issues.

Supreme Court’s Directions

The Court issued fresh binding directions:

Three-Month Limit

If a judgment is not pronounced within three months of being reserved, the Registrar General of the High Court must place the matter before the Chief Justice.

Action by Chief Justice

• The Chief Justice shall direct the concerned Bench to deliver the judgment within two weeks.
• If still not delivered, the matter shall be reassigned to another Bench for disposal.

Reporting Mechanism

Registrars must furnish monthly lists of cases where judgments remain reserved beyond permissible periods, ensuring accountability.

Circulation of Judgment

The present judgment was directed to be circulated to Registrar Generals of all High Courts for strict compliance.

Supplement to Anil Rai

These directions are in addition to the Anil Rai guidelines, not in substitution.

Ratio Decidendi

The ratio of the judgment can be distilled as follows:

• Delay in pronouncement of reserved judgments beyond a reasonable period (three months) violates the principles of fairness, speedy justice, and public confidence in the judiciary.
• The Registrar General and Chief Justice of High Courts are duty-bound to monitor, report, and ensure delivery of judgments within prescribed limits.
• In case of persistent non-delivery, matters must be reassigned to another Bench to uphold litigants’ rights.

Significance of the Judgment

1. Reassertion of Judicial Accountability: This judgment signals the Supreme Court’s strong disapproval of delays that undermine the constitutional mandate of speedy justice. It institutionalises accountability within High Courts.
2. Protection of Litigants’ Rights: By laying down a three-month rule, the Court provides litigants with a clear framework to demand timely adjudication, reducing uncertainty and prolonged mental agony.
3. Strengthening Anil Rai Guidelines: While Anil Rai (2001) had already prescribed safeguards, this case strengthens enforcement by assigning responsibility to Registrars and Chief Justices, ensuring systemic monitoring.
4. Broader Judicial Reform: The decision fits within the larger judicial reform discourse in India, tackling backlogs, delays, and pendency. It reiterates that procedural efficiency is integral to substantive justice.

Click Here to Read the Official Judgment

Conclusion

The Supreme Court’s ruling in Ravindra Pratap Shahi v. State of U.P. is a landmark attempt to confront a long-standing malaise in Indian judiciary—delayed pronouncement of judgments after hearings are concluded. By reiterating the principles of Anil Rai and supplementing them with a strict reporting and escalation mechanism, the Court has sought to uphold Article 21 rights of litigants and preserve public faith in the justice delivery system.

This decision underscores that justice delayed is justice denied, and unless judgments are delivered within a reasonable timeframe, the very legitimacy of judicial institutions stands threatened. The ruling is thus both a call to action and a reminder of the judiciary’s solemn responsibility to the people it serves.