The Supreme Court stayed portions of the Allahabad High Court judgment against Uttar Pradesh Additional Chief Secretary (Home) Sanjay Prasad, IAS. The Court suspended directions requiring adverse observations to be forwarded to the DoPT for consideration in future service-related assessments and assignments.
The Supreme Court stayed portions of an Allahabad High Court judgment that had strongly criticised Uttar Pradesh Additional Chief Secretary (Home) Sanjay Prasad, IAS, and directed that the observations against him be considered while assessing his suitability for future assignments.
A Bench comprising Justices Prashant Kumar Mishra and Atul S. Chandurkar passed the interim order while hearing an appeal filed by Prasad against the June 3 judgment delivered by the Allahabad High Court. The Supreme Court specifically stayed the directions requiring that the High Court’s findings be forwarded to the Department of Personnel and Training (DoPT) for consideration in future service-related evaluations of the senior bureaucrat.
Prasad, a 1995-batch Indian Administrative Service officer, is currently serving as Additional Chief Secretary (Home) in Uttar Pradesh. He is widely regarded as one of Chief Minister Yogi Adityanath’s most trusted bureaucrats and plays a key role in the State’s law-and-order administration.
Background of the Dispute and High Court’s Observation
The controversy arose from proceedings before the Allahabad High Court concerning a habeas corpus petition filed by a woman seeking custody of her minor daughter. The petitioner alleged that her daughter had been enticed away by a man and that despite repeated efforts, the police had failed to trace or recover the child.
As the matter progressed, the High Court examined the quality of the investigation conducted by the police authorities. The Court found serious deficiencies in the investigation and expressed concern regarding the manner in which criminal investigations were being handled across the State.
During the proceedings, the Court expanded its scrutiny beyond the individual case and began examining whether earlier directions issued by it for improving police investigations and accountability mechanisms were being properly implemented by the State administration.
The High Court’s observations stemmed from its earlier judgment in Subhash Chandra & Others v. State of Uttar Pradesh & Another, delivered in May 2025. In that case, the Court had issued several directions intended to improve the quality, fairness, transparency, and professionalism of criminal investigations in Uttar Pradesh.
The objective behind those directions was to strengthen investigative standards, enhance accountability within the police force, and ensure greater compliance with constitutional principles governing criminal justice administration. However, when the High Court examined the progress of implementation of those reforms, it found what it considered to be persistent administrative resistance and non-compliance.
Justice Vinod Diwakar noted that efforts aimed at improving the criminal justice system appeared to have encountered obstacles at various administrative levels.
The Court observed:
“The record placed before the Court indicates that, on more than one occasion, judicial initiatives intended to strengthen the quality, fairness, and accountability of criminal investigations have not received the degree of institutional support that would ordinarily be expected from the authorities entrusted with civil administration.”
During the hearing, the High Court sought an explanation from Additional Chief Secretary (Home) Sanjay Prasad regarding the alleged non-compliance with its earlier directions.
In response, the State informed the Court that it had decided to challenge the Subhash Chandra judgment before the Supreme Court. Through an affidavit filed by the Home Department, the State requested the High Court not to issue any further directions for implementation of the earlier judgment pending the proposed challenge.
The High Court, however, found the explanation unsatisfactory. Justice Diwakar pointed out that despite the judgment having been delivered nearly a year earlier, no appeal had been filed immediately. According to the Court, the decision to challenge the ruling appeared to have been taken only after questions were raised regarding implementation and compliance.
The Court further noted that although it had granted time to the State to place on record details of the proposed Special Leave Petition (SLP), no order or interim protection from the Supreme Court was produced even after several months.
While analysing the sequence of events, the High Court expressed concern regarding the conduct of Prasad. The Court observed that there appeared to be an “apparent reluctance” on his part to facilitate and effectively implement measures aimed at improving investigative standards and ensuring compliance with judicial directions.
Justice Diwakar went further and held that Prasad’s actions prima facie suggested a deliberate effort to obstruct judicially mandated reforms. The Court remarked that his conduct appeared to be a “deliberate and calculated attempt” to undermine the authority of the Court.
The judgment stated that failure by senior administrative officers to implement judicial directions could have serious consequences for constitutional governance and accountability.
The Court observed:
“Such conduct, if left unaddressed, would have the effect of rendering the orders of Constitutional Courts nugatory at the hands of recalcitrant administrative officers and would set a pernicious precedent for the manner in which judicial directions concerning accountability and police reforms may be treated by the executive. This Court cannot be a silent spectator to such conduct.”
The High Court emphasized that its directions regarding police reforms were intended to strengthen, rather than weaken, governance and public administration. Justice Diwakar clarified that the purpose of such reforms was not to diminish executive authority over policing but to ensure that investigations were conducted fairly, impartially, and in accordance with the rule of law.
The Court stressed that effective investigations form the backbone of the criminal justice system and are essential for maintaining public confidence in legal institutions. Highlighting the constitutional importance of police reforms, the Court observed:
“Any resistance to measures designed to achieve these objectives would be inconsistent with the constitutional mandate of ensuring the rule of law and strengthening public confidence in the criminal justice system.”
According to the Court, administrative reluctance to implement reforms could undermine efforts aimed at improving investigative standards and protecting citizens’ rights.
One of the most significant aspects of the June 3 judgment was the High Court’s direction to the Department of Personnel and Training (DoPT), Government of India.
The Court ordered that its findings regarding Prasad’s conduct be placed on record and taken into account whenever his suitability for future assignments, appointments, or responsibilities was assessed. The direction was unusual because it extended beyond the immediate dispute and potentially affected the future career prospects of a serving senior IAS officer. The Court believed that accountability mechanisms should apply equally to senior bureaucrats entrusted with implementing constitutional and judicial mandates.
Supreme Court Intervention
Aggrieved by these observations and directions, Sanjay Prasad approached the Supreme Court challenging the High Court’s judgment.
When the matter came up before the Bench of Justices Prashant Kumar Mishra and Atul S. Chandurkar, the Court granted interim relief by staying the directions that required the findings to be forwarded to the DoPT and considered in future service evaluations.
The Supreme Court’s intervention effectively suspends the operation of those portions of the High Court judgment until the matter is examined in greater detail.
While the stay does not amount to a final adjudication on the merits of the controversy, it provides immediate relief to the senior bureaucrat and prevents any adverse administrative consequences flowing from the High Court’s observations.
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