The Allahabad High Court, Lucknow Bench, quashed criminal proceedings that had been pending for over three decades in relation to an alleged ruckus at the Uttar Pradesh Vidhan Sabha in 1991, terming such stale trials a futile exercise and highlighting the need for a systemic approach to address long-pending and dead wood litigations. The bench, led by Justice Pankaj Bhatia, allowed applications under Section 482 of the Code of Criminal Procedure filed by two individuals who had been accused of creating a disturbance at Gate No. 1 of the Vidhan Sabha, allegedly attempting to force their way inside and damaging windshields and lights of parked vehicles during the incident. The court observed that the prosecution’s own record did not show any material suggesting the use of violence by an unlawful assembly in pursuit of a common object, nor did it establish assault or use of criminal force to deter a public servant in the discharge of his duty, important elements for sustaining charges such as rioting and related offences. The bench also noted that the charge of house trespass was not made out on the facts, since the Vidhan Sabha precinct could not be categorised as a human dwelling and there was no evidence of preparations to cause hurt, assault or wrongful restraint.
Additionally, the High Court found the charge under the mischief provision was similarly unsustainable and went on to highlight the constitutional right to a speedy trial under Article 21, noting that the excessive delay in prosecution had adversely affected this right. Despite cognizance having been taken more than thirty years earlier, the trial had not advanced meaningfully: no witness had been examined, numerous warrants had been issued without success, and in some instances accused persons had since died, leading the court to observe that the litigation had become a drain on judicial resources. In describing the ongoing exercise as futile, the court underscored the strain that such long-pending matters impose on the justice system and the lack of utility in continuing trials where evidence has long since become stale or unreachable.
While allowing the applications and quashing the proceedings, the High Court also drew attention to broader systemic concerns. It took note of submissions by the State counsel that the Uttar Pradesh Government had constituted a three-member committee, headed by the Additional Advocate General, to formulate a case management policy aimed at identifying and withdrawing stale or futile litigations, mirroring similar initiatives in other states. The court emphasised that the judiciary is starved of resources due to the explosion of litigation and that continuation of long-drawn, unproductive cases adds to this burden. It expressed hope that the committee would develop effective solutions to weed out such cases, thereby restoring efficiency in judicial functioning and removing dead wood from the extensive dockets of lower courts.
In its order, the High Court stressed that the objective of the committee was laudable and that expeditious formulation of a policy to identify and deal with obsolete or unproductive litigation would assist both the judiciary and the State administration. The bench articulated the need for proactive measures to address the backlog of cases that no longer serve any useful purpose and contribute instead to clogging the justice delivery system. Consequently, the entire proceedings pending before the District Court in Lucknow in connection with the 1991 Vidhan Sabha ruckus matter were quashed, with the court’s remarks underscoring the importance of timely justice and the inefficiencies inherent in allowing decades-old cases to linger without meaningful progress.
The judgment, delivered in the case titled Madhukar Sharma vs. State of Uttar Pradesh through Additional Chief Secretary (Home) and Another, encapsulates the court’s stance that where material is insufficient, where constitutional rights to a speedy trial are compromised by delay, and where proceedings have outlived their utility, judicial intervention is justified to bring finality and prevent wasteful consumption of scarce judicial resources. It also signals a call to the State Government to adopt a formal policy and institutional mechanism to review and dispose of stale matters, ensuring that similar dead wood of litigation is “chopped off” in future.
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