Introduction
The judiciary is often seen as the protector of constitutional morality, with the responsibility of exercising justice in the form of reasoned, speaking orders. In this sense, the Supreme Court recently condemned the Allahabad High Court for issuing “cyclostyled orders” in Phireram vs State of Uttar Pradesh & Anr, Criminal Appeal No. 3830 of 2025. The apex court reiterated that orders from constitutional courts should exhibit judicial reasoning and not mere mechanical patterns. This ruling has started discussions regarding judicial order quality, judge accountability, and the broader implications for litigants pursuing justice.
Background
The controversy started with a bulk of bail and interim orders issued by the Allahabad High Court, challenged before the Supreme Court. In reviewing the orders under scrutiny, the bench found that many of the orders were issued as “cut-copy-paste” products, with little application of judicial mind to the relevant facts of each case.
The expression “cyclostyled orders” is itself a throwback to an era before everything became digital, when documents were duplicated in bulk with duplicating machines known as cyclostyles. In current judicial language, it is a metaphor for templated, non-speaking orders that do not show sufficient reasoning.
Key Points
- Concerning Cyclostyled orders: Fairly, an order created by cyclostyling or mechanically prepared could be considered to be non-reasoned or, even reflective judicial orders when its operative part, the only part since, are merely taken from another order, and, the rationale distinct to the facts of the case is lost or diluted.
- Concerning Reasoned Orders: Article 14 of the Constitution of India provides equal protection before the law. Parties usually go to court to be provided to have the dispute considered in a thoughtfully and reasonable way. Where the Court simply mechanically provided orders without consideration, which is what occurs to litigants to have their case guaranteed that the litigant was given a fair opportunity and consideration, is the home of a reasoned order, which essentially serves as a Dogs flea collar to the fabric of natural justice between the judge and parties by providing clear assurance, the judge properly applied mind.
- Precedent against non-speaking orders: The Supreme Court’s past decisions like Assistant Commissioner, Commercial Tax Department v. Shukla & Bros SLP (C) No. 16466 of 2009 and Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan SLP (Civil) No. 20428 of 2007 have repeatedly emphasized that reasoned orders are part of judicial accountability and transparency.
- Effects on litigants: What does an unreasoned bail denial or dismissal of a petition mean for a litigant? It means they don’t know how or why their case failed. This compromises the right to an appeal since appellate courts generally can only rely upon the reasoning (reflected in the order) from the lower court in order to reason a decision. Cyclostyled orders erode confidence in the justice system.
- Judicial discipline: The Supreme Court’s reprimand makes it clear that High Courts, as courts of constitutional authority, are held to a higher standard. Their orders have not only to be followed by lower courts, but they also become law (unless overruled). Failure to articulate reasoning diminishes that duty.
Recent development
In the applied matter, the Supreme Court found that Allahabad High Court rejected or granted bail in a series of cases that used virtually the same wording, and didn’t reflect the unique facts, calibre of evidence, or the seriousness of the allegations. The apex court called this a serious failure and pointed out that whether an order reflects reason or not, every order must withstand judicial scrutiny.
The Court witnessed:
“Judicial decisions should not be handed down in a cyclostyle. Every decision must show conscious application of belief and must set forth adequate reason(s).”
The apex Court stated that judges cannot take a “template approach” when it comes to issues of personal liberty.
Therefore, the Court set aside the impugned order and ordered the High Court to revisit the matters and provide proper reasoning. This interference marks the apex court’s effort to instill judicial discipline into High Court bench discretion.
These remarks come at a particularly opportune time as, given the backlog of cases and the heavy caseloads that judges face, there exist certain checkpoints where judges will have had the chance to expedite their court functions by not applying their minds and using shortcut methods of their own. The Supreme Court made it abundantly clear that timelines do not trump justice.
Conclusion
The Supreme Court’s reprimanding of Allahabad High Court with regard to “cyclostyled orders” is a strong reminder of the judiciary’s duty to reason all of its decisions. In a justice system, where courts are the last bastion of justice, templated, non-speaking orders erode public confidence and violate the constitutionally guaranteed right to fair process.
The Supreme Court has emphasized the phrase “justice must not only be done but must be seen to be done”, meaning that there ought to be a distinct order that shows the applying of mind by the Judiciary, which a litigant is entitled to. The judgment gives a clear signal to all High Courts and subordinate judiciary that there will be no more repetitive and mechanical orders. In the long term, the intervention is expected to provide some accountability for the judiciary, improve the quality of orders, and safeguard the constitutional purpose of fair and equality. The Supreme Court’s position provided not just reprimands to the subordinate judiciary but is meant to be corrective in order to maintain integrity in the judicial process.
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Written by- Anwesha Anant
