Courts may direct expeditious disposal where repeated adjournments prejudice parties’ rights in pending proceedings.

The petitioner filed a petition under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (“BNSS”), seeking a direction for time-bound disposal of Criminal Complaint No. COMI/52/2024, titled Lakhvir Singh v. Manpreet Singh and Others, pending before the Judicial Magistrate, First Class, Malerkotla.

The complaint was instituted on 10 July 2024. The complainant’s preliminary evidence was recorded and closed on 5 December 2024, after which notice was issued to the accused on 8 January 2025.

Notices to some respondents encountered service difficulties, while respondents Nos. 3 and 4 filed their reply on 21 May 2025.

The petitioner contended that, thereafter, the trial Court repeatedly adjourned the matter on approximately 17 dates through stereotyped orders, despite the petitioner’s readiness to advance arguments.

Whether, in the circumstances of the case, the High Court should exercise its jurisdiction under Section 528 of the BNSS to direct the trial Court to decide the pending criminal complaint expeditiously.

Whether the repeated adjournments after the filing of the respondents’ reply warranted a direction for expedited disposal.

The Court applied Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which empowers the High Court to exercise its inherent jurisdiction to secure the ends of justice and prevent abuse of the process of law.

It further applied the general principle that courts are duty-bound to decide matters expeditiously because delay may prejudice the rights of parties; however, directions for time-bound disposal should not ordinarily be issued mechanically, particularly in view of the substantial pendency of cases, and should be reserved for cases involving peculiar facts and circumstances.

The Court noted that the complaint had been pending since 10 July 2024 and that the complainant’s preliminary evidence had already been completed.

Although some adjournments were initially attributable to the need to effect service upon the accused, respondents Nos. 3 and 4 had filed their reply on 21 May 2025, after which the matter was repeatedly adjourned despite the petitioner’s stated readiness to argue.

Balancing the need to avoid routine time-bound directions against the parties’ right to an expeditious adjudication, the Court found the circumstances sufficient to warrant a direction for concerted and prompt disposal.

Since the proposed order would not prejudice the respondents, the Court dispensed with issuance of notice to them.

The Court did not prescribe a fixed deadline. Any pending application was also ordered to stand disposed of.