Karnataka HC Quashes PSI’s Notice Threatening Rowdy Sheet, Says Only SP or Authorised SDPO May Issue It

The petitioner challenged a communication dated 10 June 2026 from the Police Sub-Inspector, Navanagar Police Station, stating that a rowdy sheet would be opened against him under Order No. 1059 of the Karnataka Police Manual.

The communication referred to two criminal cases against him, which the petitioner said arose from pending civil property litigation; he also contended that the cases were false.

The State argued that the communication was only a show-cause notice and that the petitioner should first submit an explanation.

The petition was brought under Articles 226 and 227 of the Constitution.

Order No. 1059(5) of the Karnataka Police Manual requires prior orders of the Superintendent of Police or Sub-Divisional Police Officer before a person’s name is entered in the Register of Rowdies; a Sub-Inspector cannot independently open a rowdy sheet.

In B.S. Prakash v. State of Karnataka, W.P. No. 4504/2021 and connected matters, decided 22 April 2022, this Court prescribed safeguards for rowdy/history sheeting, including a proposal notice allowing a representation, objective consideration of the relevant records by the approving authority, and recorded reasons for approval.

The Court held that such safeguards must be read consistently with Order No. 1059(5), and that any notice must issue from the Superintendent of Police or an authorised Sub-Divisional Police Officer, or with the latter’s prior order.

The Court read the impugned communication and found that it did not invite the petitioner to show cause or submit an explanation; instead, it stated that opening a rowdy sheet was necessary and would be done.

The Sub-Inspector had no authority to make that determination or issue such an intimation independently, because Order No. 1059(5) reserves the approval for the Superintendent of Police or Sub-Divisional Police Officer.

The communication therefore failed both the Manual’s approval requirement and the procedural safeguards in B.S. Prakash.

It directed that any notice proposing to open a rowdy sheet must be issued only by an officer not below the rank of Superintendent of Police or by a Sub-Divisional Police Officer authorised in accordance with law, and that the B.S. Prakash guidelines be applied accordingly.

The State Government was directed to issue necessary instructions or a circular to the concerned police stations, and a copy of the order was to be forwarded to it for compliance.