Vijayachandran vs The Commissioner of Police,

Court
Madras High Court

WP Crl.(MD) No. 6046 of 2026
BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT
DATED: 05-11-2026
CORAM
THE HON'BLE MRS. JUSTICE K. GOVINDARAJAN
THILAKAVADI
WP Crl.(MD) No. 6046 of 2026
CNR:{HCMD011562752026}
Vijayachandran ..Petitioner(s)
Vs
1. The Commissioner of Police,
The Commissioner of Police Officer,
Thiruchirapalli City.
2. The Assistant Commissioner of Police,
The Assistant Commissioner of Police Office,
Thillainagar Sub Division,
Thiruchirapalli City.
3. The Inspector of Police,
Wooraiyur Police Station,
Thiruchirapalli City. ..Respondent(s)
PRAYER: Writ Petition filed under Article 226 of the Constitution of
India to issue a Writ of Mandamus directing the respondents 2 and 3
herein to remove the petitioner’s name from the history sheet No.5/2023
rd
maintained by the 3 respondent within the time stipulated by this Court
by considering his representation dated 21.10.2026.
For Petitioner(s) : Mr.S.Ramakrishnan
For Respondent(s) : Mr.D.Rajaboopathy
Government Advocate (Crl. Side)
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WP Crl.(MD) No. 6046 of 2026
ORDER
The writ petition is filed seeking a direction to the respondents 2
and 3 to remove the petitioner's name from History Sheet No. 5/2023
rd
maintained by the 3 respondent, within such time as may be stipulated
by this Court, after considering the representation dated 21.10.2026
submitted by the petitioner.
2. The petitioner submitted a representation dated 21.10.2026 to the
respondents, seeking the removal of his name from the History Sheet in
H.S.No.5 of 2023 maintained by the third respondent. Since the said
representation has not been considered, the petitioner has filed the present
writ petition.
3. The issue involved in this writ petition has already been dealt
with by the Madurai Bench of this Court and detailed order has been
passed in W.P.(MD)No.19651 of 2017 on 26.09.2018. On the basis of
the above said Order, the Director General Of Police, Chennai, issued a
circular in Rc.No. 66569/Crime 3(2)/2019 dated 24.04.2019, which reads
as follows :~-
“7. From the above judgments the following principles emerge
insofar as history sheeters are concerned:
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WP Crl.(MD) No. 6046 of 2026
a. In order to facilitate the study of crime and
criminals, the Police Standing Orders provides a mechanism,
whereby every Police Station shall maintain a crime history,
which shall be a confidential record. In this record all cases of
crime that are mentioned in PSO No.742, which provides
various classes of crime, shall be entered and even an attempt
to commit those offences, are entered in the records
maintained in the Police Station.
b. These crime records maintained by the Various
Police Stations shall be reviewed every year by the Inspector
of Police of the concerned Police Station. On such review, the
Inspector of Police has to furnish a concise appreciation of the
year-s crime for the benefit of the Superior Officers and also to
make suggestions in order to improve the quality of crime
control. The review undertaken by the Inspector of Police is
not merely a catalogue of the crime in the year. It should
reflect the valuable suggestions in order to prevent such
crimes in future and to provide ways and means of handling
serious offences in an effective manner.
c. History Sheet can be opened by the concerned
Police Station under two circumstances. The first circumstance
is provided under PSO No.746, which states that the history
sheet can be opened against a person who is a resident
(permanently or temporarily) within the station limit, who is
known or believed to be addicted to commission of crime,
whether convicted or not. Here the thrust is on the habituality
or the propensity to commit a crime by a person, which is
sought to be monitored by opening a history sheet.
d. The second category of persons against whom
history sheet can be opened are the persons, who are
convicted for various offences that has been listed in PSO
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WP Crl.(MD) No. 6046 of 2026
No.747, wherein opening of the history sheet is automatic.
e. In the first category of opening history sheet,
month wise scrutiny or a close watch on the person concerned
is contemplated. Here also there is sub~categorization as,
close watch bad characters and non~close watch bad
characters. In the former, the entry shall be made month wise
and in the later, the entry shall be made once in a quarter.
What is entered is normally anything of interest in respect of
the bad character, which goes to the notice of the Police.
These records must be checked and brought up to date once in
a year. Here the main thrust is on “Current Doings“.
f. In the second category of opening history sheet,
a mere act of conviction under the offences listed in PSO
No.747 is enough. The name of the persons, who have been
convicted for those offences can be retained for a period of
two years after their release from jail.
g. PSO No.748, is the most important provision,
which deals with discontinuance of history sheet. This
provision is common to both the categories falling under PSO
Nos.746 and 747. As per PSO No.748, the Superintendent of
Police may order a closure of a history sheet at any time. But,
the Divisional Officer can order closure of history sheet only
after the expiry of the period stipulated in PSO No.747.
h. As per PSO 748, where retention of the history
sheet is considered to be necessary, even after two years of
registration, orders of an Officer of and above the rank of
Assistant Superintendent of Police/ Deputy Superintendent of
Police must be taken for extension for the first instance up to
the end of next December. For further annual extension from
January to December, separate orders must be passed every
time by an Officer of and above the rank of Assistant
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WP Crl.(MD) No. 6046 of 2026
Superintendent of Police / Deputy Superintendent of Police.
This provision is made applicable even for rowdy sheeters.
i. For the purpose of passing such orders, there
must be valid materials available on record and it cannot be
passed on the whims and fancies of the Police Officers.
Therefore, the authority empowered to extend the period of
retention of the names of the persons in the history sheet,
should record his reasons based on both objective and
subjective instructions.
j. Branding a person as a history sheeted rowdy,
taints the name and image of the person. It is true that the
entire purpose of maintaining a history sheet is to ensure
public peace. However, it should be balanced with the
fundamental right guaranteed to every citizen under Article 21
of the Constitution of India. Therefore, a fair and reasonable
decision, based on the materials, with sufficient reasons,
becomes sine qua non to retain the name of a person as a
history sheeter beyond the period stipulated in the Police
Standing Orders.
k. This Court has time and again brought the
above principle to the notice of the Higher Police Officials and
in one of the judgments in Manivanan Vs. State represented by
The District Collector, Coimbatore District and Others,
reported in (2013) 7 MLJ 501, this Court felt that there is lack
of understanding on the part of the Police in maintaining
history sheet and therefore, directed the Director General of
Police to issue necessary instructions / guidelines / circulars
with regard to the manner in which it has to be maintained and
the manner in which the orders will have to be passed for
extension of the period to continue a person as a history
sheeter.”
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WP Crl.(MD) No. 6046 of 2026
4. The above principles that have been culled out of various
decisions of this Court will now be applied to each case in order to see if
the Police officials have scrupulously followed all the Police Standing
Orders and the judgments of this Court, while retaining the name of a
person as a history sheeter, beyond the stipulated period.
5. In terms of the above circular passed by the Director General of
Police, Chennai, this Court directs the respondents 1 to 3 to consider the
petitioner’s representation dated 21.10.2026 and pass orders, on merits
and in accordance with law, within a period of six (6) weeks from the
date of receipt of a copy of this order.
6. With the above directions, the writ petition stands disposed of.
05-11-2026
Index: Yes/No
Speaking/Non-speaking order
Neutral Citation: Yes/No
sji
To
1. The Commissioner of Police
The Commissioner of Police Officer
Thiruchirapalli City
2. The Assistant Commissioner of Police
The Assistant Commissioner of Police Office
Thillainagar Sub Division
Thiruchirapalli City
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WP Crl.(MD) No. 6046 of 2026
3. The Inspector of Police
Wooraiyur Police Station
Thiruchirapalli City
4. The Additional Public Prosecutor
Madurai Bench of Madras High Court
Madurai
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WP Crl.(MD) No. 6046 of 2026
K.GOVINDARAJAN THILAKAVADI, J.
sji
WP Crl.(MD) No. 6046 of 2026
05-11-2026
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