This Article is written by Ankit Mohanty of SOA National Institute of Law
The Indian judiciary is burdened with the problem of continually delaying the pronouncement of reservation judgment which creates a twin problem that is its public confidence and right to the litigant as per the article 21 of the constitution. In Ravindra Pratap Shahi v. State of U.P. & Ors. (2025 INSC 1039), decided on August 25, 2025, by Justices Sanjay Karol That is, the Supreme Court took head-on in this judgment this systemic problem. Arising out of a criminal appeal pending since 2008 in the Allahabad High Court, the case is an example of delay post-hearing, i.e. more than three years of delay post reservation i.e. justice delayed, is justice denied. This article reviews and discusses the facts, issues, judicial observations and landmark directions that were issued to ensure accountability in High Courts reinforcing precedents such as Anil Rai v. State of Bihar (2001) 7 SCC 318.
These directions not only supplement existing guidelines but bring in certain enforceable mechanisms such as a rigid limit of three-month period for the delivery of judgment to prevent such recurrence. For the law students and lawyers, these ruling highlights the role of judicial administration in ensuring constitutional directives respecting speedy justice. By making the oversight of Registrar Generals and the intervention of Chief Justices mandatory, the Court institutionalizes the reform ensuring the judgments are not left in limbo.
Case Law
Facts of the Case and Procedure
Ravindra Pratap Shahi being the de-facto complainant in an underlying criminal matter became the appellant after the accused was convicted but it had appealed to the Allahabad High Court in Criminal Appeal No. 939 of 2008. Despite Shahi making nine requests for getting the animal listed early on, the Division Bench had heard prolonged arguments and reserved judgment on December 24, 2021, but did not pronounce judgment on the subject for more than three years. An administrative order of the Chief Justice of the Allahabad High Court on March 7, 2019, meant that cases out for more than six months until relisting, but even after that period and relisting on January 9, 2023, nothing significantly happened, because of the absence of the appellant’s counsel.
Frustrated, Shahi filed SLP (Crl.) Nos. 4509 – 4510 of 2025 Before the Supreme Court. On January 27, 2025, the Court ordered the Registrar General of the High Court to check the claims of delay to establish reservation and non-delivery. Further, on April 15, 2025, it called for expeditious disposal within three months because of the “alarming delay.” Respondents including the State of U.P. gave the procedural lapses as a cause of adjournments, but no reasons for the post-reservation inaction.
Issues Framed
The issues were that three-fold:
(1) Does delay in pronouncing reserved judgments for a long period of time violate the rights of litigants to speedy justice under Article-21?
(2) What mechanism of accountability should be adopted for High courts to ensure a timely delivery?
(3) Should the Supreme Court involve a mandatory time limit and escalation protocol? These Internet questions establish on the appellant that the delay was arbitrary, prejudicial, and made effective judicial faith on the opposite contrast to procedural excuses of respondents, from.
Arguments Presented
Shahi contended that the three plus year delay after reservation was unjust and violated rights of fair trial as well as requiring more stringent protocols by the High Court similar to the right of fair trial under Article 21. He stressed repeated futile representations, setting the denial of justice in context of the lapse to be considered systemic. Respondents countered the use of re-listing, delays which included non-appearance to such, but conceded that there was no resolution that worked after reservation after 2021.
Observations and Analysis made by the Supreme Court
The Bench expressed “shock and surprise” over the delay, which it called a malady that encroaches across High Courts to mar the “God-like” public pang while the judiciary works by law. Citing Anil Rai, the Court recalled guidelines – ideal pronouncement within two months; litigant applications post-three months; and reassignment after six months. It referred to precedents such as, State of Punjab v. Jagdev Singh Talwandi, 1984 1 SCC 596 deprecation of operative order only pronouncements: Zahira Habibulla H. Sheikh v. State of Gujarat (2004) 4 SCC 158, Mangat Ram v. State of Haryana, 2008 (7) SCC 96; Ajay Singh vs. State of Chhattisgarh (2017) 3 SCC 330; Balaji Baliram Mupade vs. State of Maharashtra 2021 12 SCC 603; Ratilal Jhaverbhai Parmar vs. State of Gujarat (2024 INSC 801); and K. Madan Mohan Rao v. Bheemrao Baswanthrao Patil. No 1025 INSC 2022.
The Court put emphasis on gaps in enforcement: The rules are there but enforcement deficits without monitoring. Delays cause mental agony, limbo uncertainty, and public distrust against speedy justice imperatives. Unlike isolated cases, this is the reflection of pending crises demanding administrative rigor.
Directions Issued
Innovating beyond Anil Rai the Court mandated
Three Month Threshold: After taking time for delivery, if it is not delivered in 3 months, the Registrar General lists for Chief Justice.
Chief Justice Intervention: Orders Bench to pass its judgment within two weeks.
Reassignment Protocol: Non-compliance is covered by fresh hearing by another Bench.
Monthly Reporting: Registrar Generals provide lists of an overdue reserved judgment.
Circulation: Judgment passed to all High Court Registrar Generals for compliance. These are in addition to, but do not replace, previous guidelines and provide for systemic accountability.
Ratio Decidendi
The ratio decidendi, which includes the following: Reserved judgments for more than three months (mandatory escalation required) non-ecocultural delays (Question: Reassignment is the sole solution to preserve the rights of the accused and the credibility of the judiciary. High Courts would need to make pronouncement as part of adjudication to be given priority.
Conclusion
Ravindra Pratap Shahi v. State of U.P. the Fortification of Judicial timelines, turning rhetoric into norms to be actually enforced against delays in judgment. By empowering the Chief Justices and the Registrars, it promotes self-regulation, which revitalizes the public trust under the backlogs. This ruling is positive for reform: it reminds the courts that the efficiency of procedures is the foundation of substantive justice or at least non-compliance may infringe on institutional legitimacy. Ultimately, it protects litigants from limbo, the administration is brought in line with the constitutional ethos.
Frequently Asked Questions
Why did the Supreme Court intervene in this case?
The Allahabad High Court, after reserving a judgment of a criminal appeal on December 24, 2021, had failed to date to deliver the judgment for more than three years, despite prods from the Supreme Court.
What is the difference in this judgement with Anil Rai v. State of Bihar?
It has been added to Anil Rai as follows: Addition of three months trigger for registrar general to report and two-week Chief Justice directive, leading to reassignment.
What exactly is the new three-month rule?
If a judgment is reserved beyond three months it is ordered to be listed before the Chief Justice who orders delivery within two weeks or orders it to be re-assigned.
The High Courts that are affected?
All High Courts The judgment orders it to be circulated to the Registrar Generals to be strictly complied with.
Can litigants now come to courts for delay of judgment?
Yes, post-three months and they can invoke these directions (and with escalation ensure accountability to).
References
- Apslaw.co.in, Case Summary: Ravindra Pratap Shahi v. State of U.P. & Ors. (2025 INSC 1039) – Directions to High Courts on Reserved Judgments, https://apslaw.co.in/case-summary-ravindra-pratap-shahi-v-state-of-u-p-ors-2025-directions-to-high-courts-on-reserved-judgments/ (last visited Feb. 2, 2026).
- Lawcurb.in, Ravindra Pratap Shahi vs State of UP & Ors (2025 INSC 1039), https://www.lawcurb.in/judgements/ravindra-pratap-shahi-vs-state-of-up-&-ors (last visited Feb. 2, 2026).
- Supreme Court Cases, Ravindra Pratap Shahi v. State of U.P. and Others (2025 INSC 1039), https://www.supremecourtcases.com/ravindra-pratap-shahi-v-state-of-u-p-and-others/ (last visited Feb. 2, 2026).
- Taxguru.in, Supreme Court Issues Directions on Delayed High Court Judgments – Ravindra Pratap Shahi Case, https://taxguru.in/corporate-law/supreme-court-issues-directions-delayed-high-court-judgments.html (last visited Feb. 2, 2026).
- Anil Rai v. State of Bihar, (2001) 7 SCC 318 https://share.google/6j3BaNFjuNDBJvii5 (last visited Feb. 2, 2026).
- State of Punjab v. Jagdev Singh Talwandi, (1984) 1 SCC 596 https://share.google/JqgUnrsBM1eivMObA (last visited Feb. 2, 2026).
- Zahira Habibulla H. Sheikh v. State of Gujarat, (2004) 4 SCC 158 https://share.google/83XnzOKguRp28G1E9 (last visited Feb. 2, 2026).
- Mangat Ram v. State of Haryana, (2008) 7 SCC 96 https://share.google/Hqx7oWR6AABtruvMg (last visited Feb. 2, 2026).
- Ajay Singh v. State of Chhattisgarh, (2017) 3 SCC 330 https://share.google/NHJDvDB1oeS4NWte3 (last visited Feb. 2, 2026).
- Balaji Baliram Mupade v. State of Maharashtra, (2021) 12 SCC 603 https://www.casemine.com/judgement/in/5fa0f18eaf2b5dce162ee5f4 (last visited Feb. 2, 2026).
- K. Madan Mohan Rao v. Bheemrao Baswanthrao Patil, 2022 INSC 1025 https://share.google/QLt89UvPF5ifXPTVA (last visited Feb. 2, 2026).
