Madras High CourtAdministrative and Public LawCriminal Law

Madras HC Gives Police Six Weeks To Decide Man’s Plea To Remove His Name From History Sheet

M.Syed Ibrahimv.The State of Tamil Nadu Rep., by

Madras HC Gives Police Six Weeks To Decide Man’s Plea To Remove His Name From History Sheet. M.Syed Ibrahim vs The State of Tamil Nadu Rep., by. Madras High Court. LawLens
The LawLens card for this judgmentXLinkedInWhatsApp

In brief

The question

Whether the respondents should be directed to consider the petitioner’s representation seeking removal of his name from the History Sheet

The court held

The Court disposed of the writ petition without ordering immediate removal of the petitioner’s name from the History Sheet.

It also directed

It directed respondents 1 to 3 to consider the petitioner’s representation dated 11 October 2026 and pass orders on merits and in accordance with law within six weeks from receipt of a copy of the order.

01Facts

The petitioner sought removal of his name from the History Sheet maintained by the fourth respondent and submitted a representation dated 11 October 2026.

pp. 1–2 · ¶ 1–2

As the representation had not been considered, he filed this writ petition under Article 226.

pp. 1–2 · ¶ 1–2

The Court referred to its earlier order in W.P.(MD) No. 19651 of 2017, dated 26 September 2018, and the Director General of Police’s circular dated 24 April 2019 concerning the maintenance and retention of history sheets.

pp. 2–5 · ¶ 3

02Issues

i.Whether the respondents should be directed to consider the petitioner’s representation seeking removal of his name from the History Sheet

p. 1 · p. 6 · ¶ 5

ii.Whether the Court should itself order removal of the petitioner’s name from the History Sheet

pp. 1–2 · ¶ 1–2

03Law Applied

Article 226 empowers the High Court to issue appropriate directions to public authorities.

Under the principles set out in the Director General of Police’s circular, a history sheet may be opened under Police Standing Order (PSO) 746 for a person believed to be habitually or predisposed to committing crime, or under PSO 747 for persons convicted of specified offences.

pp. 3–5 · ¶ 3

PSO 748 governs discontinuance and retention: where continued retention is considered necessary beyond the prescribed period, it requires orders by an officer of the prescribed rank, supported by valid material and reasons; the decision must be fair and reasonable and balance public peace with the individual’s rights under Article 21.

pp. 3–5 · ¶ 3

These principles were drawn from the earlier decision in W.P.(MD) No. 19651 of 2017 and the authorities referred to in the circular, including Manivanan v. State [(2013) 7 MLJ 501].

p. 2, 5 · ¶ 3

04Reasoning

The Court applied the circular’s requirements for reviewing and retaining history sheets, but did not assess whether the petitioner’s history sheet should, on its merits, be removed.

p. 6 · ¶ 5

Because the petitioner’s representation remained undecided, the Court directed the first to third respondents to consider it on its merits and in accordance with law, applying the relevant principles.

p. 6 · ¶ 5

05Holding

The Court disposed of the writ petition without ordering immediate removal of the petitioner’s name from the History Sheet.

p. 6 · ¶ 5–6

It directed respondents 1 to 3 to consider the petitioner’s representation dated 11 October 2026 and pass orders on merits and in accordance with law within six weeks from receipt of a copy of the order.

p. 6 · ¶ 5–6
Madras High Court

Original Court PDF

M.Syed IbrahimvsThe State of Tamil Nadu Rep., by

Madras High Court · November 05, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment