In a significant ruling, the Supreme Court of India has emphasized that delays in filing writ petitions should not lead to outright dismissal if fundamental rights are at stake. Delivering its judgment in Civil Appeal No. 13806 of 2024 (Ram Autar Singh Yadav v. State of Uttar Pradesh & Ors.), the Court set aside a 2023 order of the Allahabad High Court and underlined the duty of constitutional courts to uphold fundamental rights, even in cases of procedural delays.
The three-judge bench of Justice Surya Kant, Justice Dipankar Datta, and Justice Ujjal Bhuyan observed, “No argument can commend acceptance that a litigant seeking enforcement of his fundamental right should be denied relief solely due to delay.” The ruling reinstates the balance between judicial discretion and the duty to protect constitutional rights.
Background of the Case
The case revolved around an extraordinary act of bravery by the appellant, Ram Autar Singh Yadav, a retired Sub-Inspector of Police in Uttar Pradesh. In March 1986, Yadav thwarted a gang of armed dacoits who had ambushed a passenger bus. Using his service revolver, he neutralized a hardened criminal, Chhidawa, saving numerous lives. His valiance was commended by senior police officers, and his name was recommended for the President’s Police Medal for Gallantry in 1989.
Despite this recommendation, no action was taken. Years after his retirement, Yadav approached various forums seeking recognition and benefits, but to no avail. His petition was dismissed by the Allahabad High Court in August 2023 on the grounds of “inordinate delay,” a decision now reversed by the Supreme Court.
Legal Issues and Observations
The Supreme Court dealt with two primary issues:
1. Whether the High Court was justified in dismissing the writ petition solely due to delay
The Court ruled that while delay is a factor, it cannot override the enforcement of fundamental rights, particularly under Articles 14 and 21 of the Constitution. It referred to State of Madhya Pradesh v. Nandlal Jaiswal and reiterated that procedural delays should not stand in the way of justice when no third-party rights are affected.
2. Recognition of the appellant’s gallantry and rightful entitlement to an award
The Court held that the appellant’s act of valor fulfilled all criteria for the President’s Police Medal. It criticized the State authorities for failing to act on the recommendation made in 1989 and described the eventual token reward of Rs. 1 lakh as “a poor consolation prize.”
Court’s Decision
In a strong rebuke to the Allahabad High Court’s “mechanical dismissal,” the Supreme Court remarked, “The High Courts must be mindful of their role as guardians of fundamental rights. They should not mechanically dismiss writ petitions on the ground of delay without considering all relevant factors.”
The apex court awarded Yadav an additional Rs. 4 lakh, bringing the total compensation to Rs. 5 lakh, as a token of appreciation for his bravery. It directed the State of Uttar Pradesh to ensure the dignified presentation of the reward by January 26, 2025.
