Chief Justice-Centric Model Of HC Administration Requires Recalibration; Marginal Role Of Puisne Judges Runs Counter To Participatory Decision-Making: Allahabad High Court

The Court recorded that 16,15,655 criminal cases in Uttar Pradesh remain pending without charge being framed, some dating to 1981. It also recorded that after August 12, 2025 district courts directed two sureties in 9,775 anticipatory and 1,56,155 regular bail orders, despite the directions in Smt. Bacchi Devi v. State of U.P. (2025) SCC OnLine All 5286. It requested the Chief Justice to explore convening Full Courts and ensuring compliance with the Allahabad High Court Rules, 1952.

A Bench of Justice Vinod Diwakar observed, “The prevailing Chief Justice-centric model of High Court administration requires recalibration in favour of a more deliberative and institutionally balanced approach. The marginal role of puisne judges in administrative matters runs counter to broader administrative theories that emphasise participatory decision-making and institutional accountability”.

“The purpose of taking the discussion to the next level is not to cast aspersions on any individual or to undermine the authority vested in the office of the Chief Justice, but to initiate a constructive dialogue aimed at reaching a logical conclusion informed by fresh perspectives and new ideas”, it further noted.

Advocate Arun Pratap Singh appeared for the petitioner and Senior Advocate Manish Goyal appeared for the respondent.

“There is another aspect attached to this proposition, namely, the ‘personal identity’ and ‘dignity’ associated with the office of a Judge. When these are compromised, they may influence judicial behaviour. Instances of disregarding the Rules of Court, 1952, and failing to record individual concurrence or dissent in Full Court meetings may give rise to a perception of disrespect towards an individual’s personal identity and dignity. If such instances are not addressed with restraint, they carry the potential risk of eroding institutional discipline and undermining the rule of law. Any tendency to respond on the basis of personal affront or subjective considerations of identity may lead to arbitrariness, bias, and a departure from established legal norms. Such reactions are incompatible with the principles of procedural fairness and natural justice and may ultimately weaken public confidence in judicial institutions”, the Bench had also noted.

In the matter, four petitions under Article 227 of the Constitution of India were decided together, Pappu Met challenged a bail order requiring a Rs. 1,00,000 bond and two sureties in a buffalo-theft case, though co-accused had been released on Rs. 25,000. Urmila Mishra sought disposal of a case pending since 2009, listed over 178 times without charge. Sarfraj Ahmad's 2008 FIR had seen 143 listings, and V.S. Palitube's 2013 cheque-dishonour complaint for Rs. 59,000 had seen over 100.

On December 11, 2025 and December 18, 2025, the Court sought explanations from the judicial officers concerned and the District Judge, Bareilly, who reported 2,326 non-compliant bail orders. On December 16, 2025 the Court called for year-wise data on pending cases from all districts, and on February 11, 2026 it found most reports incomplete or non-compliant, granting further time.

The Court observed that officers tend to follow established practice, are sometimes overly cautious about reversal, and cite judgments formally without applying their reasoning. Relying on the Oxford Handbook of Comparative Judicial Behaviour, it also pointed to staff vacancies, inadequate training and weak supervision. It further noted that only 16 Full Court meetings were held in ten years, though it said these administrative paragraphs were not directly relevant to disposing of the petitions.

“Collectively, the aforesaid cases disclose a concerning pattern of procedural stagnation before the District Courts, and, equally, no effective attention has been paid at the level of this Court. It underscores the need for timely and effective intervention, so that the rule of law is upheld and the ends of justice are not defeated by mere avoidable delay. It is not an attribute of the individual alone, it reflects the behavioural pattern of the institution in the dispensation of justice. Several factors appear to contribute to this state of affairs. There is no notified national policy governing the administration of justice, nor any settled procedure or codified rules prescribed for it. Sustained, effective and result-oriented training and learning programmes for Judges are wanting programmes that would bring consistency to judicial pronouncements and help to build judicial character”, the Bench said.

“Two intertwined concerns emerge from the facts of the cases discussed hereinabove, from the compliance reports furnished by the learned District Judges, from the empirical data examined, and from the records and orders perused. The first is the manner in which information called for by this Court has been responded to by the courts below, coupled with an apparent difficulty in comprehending and applying the judgments of the constitutional courts. The second is that these difficulties are compounded by wider structural factors - among them the limitations of judicial self-governance, the vulnerabilities arising from internal dependence, deficiencies in institutional resources, and the absence of a congenial atmosphere for a coherent work culture”, the Bench has also noted.

Pappu Met's petition was allowed, the bail order having been modified earlier to a Rs. 5,000 bond with one surety. In Urmila Mishra, the ACJM, Prayagraj, must decide the case in a time-bound manner, with reasoned orders on exemption applications, forfeiture of bonds where warranted, and action against erring police officers. Sarfraj Ahmad follows the same directions. In V.S. Palitube, the trial court must expedite the complaint, and the SSP, Kanpur Nagar, must ensure the accused's presence. The judgment is to go to the Chief Justice and the Department of Justice, and the record is to be digitised.

“The difficulty experienced by a trial court in comprehending and applying the judgments of the constitutional courts is not merely an individual shortcoming. It is a systemic issue, rooted in institutional arrangements, legal education, the design of judicial training programmes, and institutions’ behavioural patterns. A principal reason lies in systemic institutional constraints and psychological and behavioural patterns that to shape and contribute judicial behaviour”, the judgment read.

Cause Title: Pappu Met @ Pappu v. State of U.P. and Another (Neutral Citation: 2026:AHC:204628)

Appearances:

Petitioner: Arun Pratap Singh and Kamaluddin, Advocates.

Respondent: Manish Goyal, Senior Advocate, Sudhir Mehrotra, Rajeev Sawhney, Pratima Vishwakarma and Juveriya Kazmi, Advocates.

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