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Supreme Court Orders Inquiry into Registry’s 3-Year Delay in Bail Cancellation Plea Listing

Bench Calls Delay a “Disturbing Factor” and Seeks Accountability from Registry Officials

Case Linked to Former Tamil Nadu Minister’s Bail; Petition Became Infructuous After High Court Quashed FIR

By Our Legal Reporter

New Delhi: September 24, 2025: In a rare move, the Supreme Court of India has ordered an internal inquiry into its own Registry after discovering a three-year delay in listing a bail cancellation plea. The Court described the lapse as a “disturbing factor” and directed the Registrar (Judicial) to identify the officials responsible for the delay.

The case involved a petition challenging the bail granted to former Tamil Nadu minister and AIADMK leader M. Manikandan in a sexual offence case. However, by the time the matter was finally listed in September 2025, the Madras High Court had already quashed the criminal proceedings following a settlement between the parties, rendering the petition infructuous.

Background of the Case

The complainant, a Malaysian national, accused Manikandan of sexual exploitation during a five-year live-in relationship. She alleged that she was forced to undergo multiple abortions and threatened with exposure of private photographs if she pursued marriage or legal action.
In July 2021, the Madras High Court granted conditional bail to Manikandan.
The complainant challenged this order in the Supreme Court through a Special Leave Petition (SLP) filed in 2022.
On May 13, 2022, a bench led by then Chief Justice N.V. Ramana, along with Justices J.K. Maheshwari and Hima Kohli, issued notice to the respondents and directed the Registry to list the matter “immediately after service is complete.”
Service was completed on May 30, 2022, but the case was not listed for over three years.

Court Proceedings in 2025

When the matter finally came up before a bench of Justices J.K. Maheshwari and Vijay Bishnoi on September 23, 2025, the State of Tamil Nadu informed the Court that the High Court had already quashed the FIR in July 2022 after the complainant and Manikandan reached a settlement.

The bench observed that since the FIR itself had been quashed, the plea for cancellation of bail had become infructuous. The Court dismissed the petition but noted with concern the serious procedural lapse in its Registry.

Court’s Observations

The bench made several strong remarks:

On the delay: “One disturbing factor is still there that while issuing notice by this Court on 13.05.2022, the Registry was directed to list this matter immediately after service is complete. As per the office report, Respondent Nos. 1 and 2 were served on 30.05.2022. Even thereafter, the case is not listed by the Registry.”
On accountability: The Court directed the Registrar (Judicial) to conduct an inquiry and submit a report within two weeks, identifying the official(s) responsible for the delay.
On systemic issues: The Court stressed that bail-related matters must not be left pending for years, as such delays undermine the justice system.

Why the Delay Matters

The Supreme Court’s intervention is significant for several reasons:

Erosion of Trust: Delays in listing cases, especially those involving bail and personal liberty, can erode public trust in the judicial system.
Impact on Victims: In this case, the complainant’s plea for cancellation of bail was never heard on merits because of the Registry’s inaction.
Judicial Accountability: By ordering an inquiry into its own Registry, the Court has signaled that administrative lapses within the judiciary will not be ignored.

The Larger Context

This is not the first time the Supreme Court has flagged delays in its Registry. In earlier cases, the Court has expressed concern over:

Long pendency of bail matters: The Court has repeatedly directed that bail-related petitions should be listed promptly.
Administrative inefficiency: Delays in listing cases despite judicial orders raise questions about internal monitoring mechanisms.
Impact on justice delivery: Procedural lapses can change the course of cases, as seen here where the petition became infructuous due to the delay.

The Case of M. Manikandan

Political Background: Manikandan served as the Information Technology Minister in the previous AIADMK government in Tamil Nadu.
Allegations: The complainant alleged sexual exploitation, forced abortions, and threats.
Defense: Manikandan denied the allegations, claiming the relationship was consensual and accusing the complainant of extortion.
High Court’s Role: In July 2022, the Madras High Court quashed the FIR after the complainant and Manikandan reached a settlement.

The Supreme Court noted that since the FIR itself was quashed, the bail cancellation plea could not survive.

Reactions to the Judgment

Legal experts have described the Supreme Court’s order as a rare instance of judicial introspection. By holding its own Registry accountable, the Court has set a precedent for transparency and efficiency.

Lawyers’ View: Senior advocates have welcomed the move, saying it will push for better case management within the judiciary.
Public Concern: For ordinary citizens, the case highlights how procedural lapses can deny justice, especially in sensitive matters like sexual offence cases.

What Happens Next

The Registrar (Judicial) has been directed to:

Conduct a formal inquiry into the delay.
Submit a report within two weeks in chambers.
Identify the official(s) responsible for the lapse.

The outcome of this inquiry could lead to disciplinary action against Registry staff and reforms in case-listing procedures.

Conclusion

The Supreme Court’s order in this case is a reminder that justice delayed is justice denied. By calling out its own Registry for a three-year delay, the Court has shown a willingness to confront internal inefficiencies.

While the complainant’s petition could not be heard due to the quashing of the FIR, the Court’s strong words and inquiry order may pave the way for systemic reforms. For the judiciary, this is not just about one case—it is about ensuring that procedural lapses do not undermine the rule of law.

SC Orders Probe into Registry’s 3-Year Bail Plea Delay