Allahabad High Court: State Machinery and Police Bear Primary Responsibility for Criminal Case Pendency — 'Tarikh Pe Tarikh' Referenced

Overview of the Judgment

In a remarkably candid and far-reaching judicial pronouncement, the Allahabad High Court recently delivered a judgment that cuts to the heart of one of India's most persistent legal challenges — the staggering pendency of criminal cases in district courts. The case, Mevalal Prajapati Vs State of U.P., arising from Criminal Misc. Bail Application No. 11476 of 2026, cited under Neutral Citation No.: 2026:AHC105379, was decided on May 7, 2026 by a Single Judge Bench presided over by Hon'ble Mr. Justice Arun Kumar Singh Deswal.

What makes this ruling particularly noteworthy is not merely the bail application at its center, but the sweeping observations the Court chose to record — placing accountability for judicial delays squarely at the doorstep of the State Government and its police machinery, rather than attributing the burden solely to the judiciary.

Drawing upon the iconic dialogue from the 1993 Bollywood blockbuster Damini — "Tarikh pe Tarikh, Tarikh pe Tarikh milti rahi hai… lekin insaf nahi mila My Lord, insaf nahi mila! Mili hai to sirf tarikh" — the Court acknowledged the popular frustration embedded in those words while simultaneously clarifying that judicial officers are themselves victims of systemic failures rather than architects of delay.

Background and Procedural History of the Bail Application

The Underlying Criminal Case

The bail application was filed on behalf of the applicant seeking release during trial in Case Crime No. 290/2025, registered under Sections 103(1), 238, 309(6), and 317(2) of the Bhartiya Nyay Sanhita (B.N.S.), at Police Station Husenganj, District Fatehpur.

Hearings and Preliminary Observations

The matter came up for hearing on multiple dates — 07.04.2026, 15.04.2026, and 24.04.2026. During these proceedings, the Court identified a glaring investigative lapse: although a blood-stained screwdriver had been submitted for Forensic Science Laboratory (FSL) examination, the Investigating Officer had never sought clarification from the FSL regarding whether the blood on the weapon matched that of the deceased.

This discovery prompted the Court to summon the Director, FSL, Uttar Pradesh, Lucknow, to appear and assist the Court. The Director appeared on 29.04.2026 and made several critical disclosures that served as a springboard for the Court's broader observations.

What the FSL Director Revealed

The revelations placed before the Court by the FSL Director painted a deeply concerning picture of the state of forensic infrastructure in Uttar Pradesh:

  • DNA profiling timelines: A fresh blood sample can yield a DNA profile within 3 to 4 days, and even degraded samples can be processed if collected carefully and high-end equipment is available.
  • Limited facilities: Out of 12 FSLs functioning across Uttar Pradesh, only 8 possess the capability to generate DNA profiles.
  • Staff and equipment shortages: The FSLs face acute shortages of both qualified personnel and modern instruments required for forensic and ballistic testing.
  • Lack of administrative autonomy: The U.P. FSL is not an autonomous body under the Home Department — it operates as part of the police department, restricting its ability to independently procure instruments or recruit staff.
  • Central Government's pending directive: The Ministry of Home Affairs, Government of India, has sent multiple communications to the State Government urging that the U.P. FSL be granted autonomous status under the Home Department, yet the matter remains unresolved.

These disclosures led the Court to further direct the Director General of Police and the Additional Chief Secretary (Home), U.P., to appear via video conferencing to assist the proceedings.

The Court's Core Observations

Judicial Officers Are Frustrated — Not Indifferent

In paragraph 17, the Court offered what is perhaps its most powerful observation of the entire judgment: