The Allahabad High Court has expressed serious concern over the failure of district courts to follow binding directions on bail and surety conditions, observing that “Judicial discipline is not a matter of choice; it is a constitutional imperative that sustains the hierarchy of courts and ensures coherence and certainty in the administration of justice.”
The court also said that “When judicial orders are disregarded, not only is the rule of law undermined, but the faith of the people-on which the very foundations of a healthy democracy rest – stands shaken.”
Justice Vinod Diwakar passed the judgment on September 28, 2026, in a batch of four petitions, including the petition filed by Pappu Met alias Pappu against the State of Uttar Pradesh and another.
The court was dealing with a common concern relating to delays in trial proceedings and the apparent failure of district courts to furnish information sought by the High Court.
In Pappu Met’s case, the petitioner had challenged the order dated November 19, 2025, passed by the Additional Sessions Judge, Bareilly, concerning modification of his bail order.
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The case arose from an FIR registered at Bithri Chainpur Police Station in Bareilly under Sections 305, 317(5) and 331(4) of the Bharatiya Nyaya Sanhita, 2023, against unknown persons over the alleged theft of two buffaloes and a calf.
During the investigation, the animals were recovered from co-accused Hafeej Ahmad, Toufil Ahmad and Mohd. Kasif.
The petitioner’s name subsequently surfaced, following which he was arrested, sent to jail and included as an accused in the charge-sheet.
The petitioner was granted bail but was required to execute a personal bond of Rs.1 lakh and furnish two sureties of the same amount.
His counsel submitted that the co-accused, including those from whose possession the case property had been recovered, had been released on a personal bond of Rs.25,000 and two sureties of the like amount.
It was argued that the petitioner had extremely limited means and was unable to furnish sureties of such magnitude.
The High Court noted that its earlier judgment in Smt. Bacchi Devi vs. State of U.P. and Another [2025 SCC OnLine All 5286] had issued comprehensive directions concerning bail and sureties.
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It found that the directions had not been adhered to by the courts below and that there had also been a failure by District Judges to furnish information repeatedly called for by the High Court.
The court said the issue had to be examined in the context of “constitutional scheme, judicial discipline, institutional accountability” and its supervisory jurisdiction under Article 227 of the Constitution.
The court further recorded that its earlier order had found that the Additional District and Sessions Judge had “either not comprehended the directions properly, or has misunderstood the same, or is otherwise not willing to adhere to the directions, for reasons best known to them.”
It observed that the matter was not an isolated instance and that the High Court was regularly receiving applications seeking modification of bail orders passed in disregard of Bacchi Devi and earlier Supreme Court judgments.
The extent of non-compliance came to light from data supplied by the Bareilly district judiciary. The District Judge reported that, after the Bacchi Devi judgment, its directions were not followed in 2,326 cases across 47 courts of the Judgeship.
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The High Court subsequently obtained district-wise data from across Uttar Pradesh.
The judgment records that in 9,775 anticipatory bail orders and 1,56,155 regular bail orders passed after August 12, 2025, accused persons had been directed to furnish two sureties, contrary to the directions in Bacchi Devi.
The court also found serious deficiencies in compliance reports submitted by District Judges.
It observed that “none of them has filed a compliance report in terms of the directions contained in the order dated 18.12.2025 passed in Pappu Met despite repeated orders and reminders.”
It added that compliance with such directions “is not a single event but a continuing obligation.”
On the wider issue of judicial functioning, the court observed that judicial character requires sustained training and institutional support, including accountability for administrative decisions, corrective measures for breaches of discipline and programmes aimed at cultivating fraternity and a spirit of brotherhood.
It further held that constitutional morality and judicial character “are not innate attributes; they require to be cultivated through sustained training and learning.”
The court ultimately recorded that the prayer in the Pappu Met petition had already been allowed by its order dated December 11, 2025.
The impugned bail order was directed to be modified so that the petitioner would be released on executing a personal bond of Rs.5,000 and furnishing one surety in the like amount, to the satisfaction of the concerned court.
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The petition accordingly stood allowed.
The judgment also dealt with the other three petitions concerning prolonged criminal proceedings. In Urmila Mishra’s case, the court directed the Additional Chief Judicial Magistrate, Prayagraj, to decide a criminal case pending since 2009 in a time-bound manner.
The court noted that the case had been listed more than 178 times without even reaching the stage of framing of charge.
In Sarfraj Ahmad’s case, an FIR lodged in 2008 and charge-sheet filed in 2010 had been followed by approximately 143 listings without meaningful progress.
The court observed that these cases disclosed “not isolated lapses but a persistent difficulty in securing timely compliance, the framing of charge, and the progression of criminal trials to their logical end, besides other infrastructural and judicial behaviour patterns”
It noted that 16,15,655 cases were pending in Uttar Pradesh in which charges had not been framed, including 14,08,134 before Magistrates and 2,07,521 before Sessions Courts, with the pendency extending back to 1981.
Case: Pappu Met @ Pappu vs State of U.P. and Another
Case No: Matters Under Article 227 No.15205 of 2025
Date of Order: 28.09.2026
Status: Disposed of
