Continuation of a rowdy-sheet entry must be reconsidered in accordance with prescribed procedural safeguards.

The petitioner challenged the Deputy Superintendent of Police’s order dated 24 August 2017 entering his name in the Register of Rowdies and sought its deletion.

He contended that the entry was made without following the requirements of Order 1059 of the Karnataka Police Manual and without properly assessing whether his conduct brought him within the definition of a rowdy.

The State submitted that the entry was made because his activities and involvement in criminal cases were considered detrimental to public peace and tranquillity.

1. Whether the petitioner’s entry in the Register of Rowdies, and its continuation, complied with the procedural requirements and guidelines governing rowdy-sheet registration.

2. Whether the Court should direct the respondents to reconsider the continuation of the petitioner’s name in the Register of Rowdies.

The Court relied on Order 1059 of the Karnataka Police Manual, including the requirement that the competent authority call for and objectively consider the relevant records before approving an entry, and Order 1057(2), which provides for periodic review of entries.

It applied the guidelines in Sri B.S. Prakash v. State of Karnataka and Others, W.P. No. 4504/2021, decided on 22 April 2022. Those guidelines require the police to collect relevant material, ordinarily issue a proposal notice allowing the individual to make a representation, record reasons for approval, periodically review the entry, and provide a process for seeking review and approaching the Police Complaints Authority.

Applying the B.S. Prakash guidelines, the Court considered the impugned order and concluded that it did not meet the requirements of law.

It therefore held that the authorities were required to reconsider whether the petitioner’s name should remain on the Register of Rowdies, rather than directing immediate deletion of the entry.

The Court issued a mandamus directing Respondent No. 2 to reconsider whether the petitioner’s name should continue in the Register of Rowdies, in accordance with the B.S. Prakash guidelines.

The exercise was to be completed within three months of receipt of the order; no order as to costs was made.