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2025 Supreme(Online)(Mad) 60034

IN THE HIGH COURT OF JUDICATURE AT MADRAS
B.PUGALENDHI, J
Saravanan – Appellant
Versus
The State of Tamilnadu, Rep by the Superintendent of Police, District Police Office, Thanjavur District. – Respondent
W.P.Crl.(MD)No.555 of 2025



Advocates:
For the Appellant: Mr.M.Karunanithi
For the Respondents: Mr.E.Antony Sahaya Prabhakar, Additional Public Prosecutor

The necessity for periodic review of police history sheets is essential to avoid unjust derogatory implications on individuals with no recent offenses.

Headnote:(A) Constitution of India - Article 226 - Writ of Mandamus - The petitioner seeks removal of his name from the history sheet maintained by police - Respondent claims multiple pending cases against the petitioner, but some ended in acquittal - The court directs police to review necessity of history sheet as per PSO-748. (Paras 2-7)

(B) Police History Sheet - Review - Historical sheets must be reviewed periodically as per standing orders; failure to do so may lead to unnecessary implications on the individual concerned. (Paras 7)

Facts of the case:
The case involves the petitioner challenging the maintenance of his name in a police history sheet, arguing he has not committed any crimes in recent years.

Findings of Court:
The court mandated that the police shall review the history sheet against the petitioner within four weeks.

Issues: The key issue was whether the continuing existence of the history sheet was justified given the absence of new criminal activities by the petitioner.

Ratio Decidendi: The court emphasized the requirement for periodic review of history sheets as per police standing orders to prevent unjust tracking of individuals without recent offenses.

Result: The writ petition is disposed off with directions.

Table of Content
1. petitioner challenges his name on police history sheet. (Para 2)
2. claims of pending cases and acquittals presented. (Para 3 , 4)
3. court orders review of history sheet. (Para 6 , 7)

O R D E R

The petitioner has filed this application seeking a direction to the respondent police to remove the petitioner's name from the history sheet in H.S.No.210 of 2022 maintained by the third respondent.

2.It appears that the respondent police has opened a history sheet as against this petitioner in H.S.No.200 of 2020. The petitioner has studied law and now he is working in a private firm at Chennai. He never visited his village and he has not involved in any case in the past three years. Even then the respondent police has not revoked the history sheet registered as against the petitioner. Therefore the petitioner is before this Court.

3.The learned Additional Public Prosecutor submits that the petitioner is involved in Crime No.426 of 2015, registered for the offence under Sections 147, 294(b), 323, 341 and 506(i) of IPC, Crime No.84 of 2018, registered for the offence under Section 341, 294(b), 323 and 506(i) of IPC, Crime No.921 of 2022, registered for the offence under Section 294(b), 323, 355, 427 and 307 of IPC r/w TNWH Act, Crime No. 922 of 2022, registered for the offence under Sections 341, 294(b), 324, 353, 186 and 506(ii) of IPC and Crime No.47 of 2024, registered for the offence under Sections 4A(1b) - TNOPPD Act. Out these five cases, the FIR in Crime No.84 of 2018 was ended in acquital and the case in Crime No.921 of 2022 was quashed by this Court in Crl.O.P(MD)No.22741 of

2023, dated 22.12.2023.

4.According to the learned Additional Public Prosecutor, three cases are pending against the petitioner. The other case in Crime NO.426 of 2015 was registered in the year 2015 and still pending trial. With regard to the case in Crime No.922 of 2022, the respondent police claims that they have filed final report. However, it has not been taken on file. The other case in Crime No.47 of 2024 is only for the offence under Section 4A(1b) of Tamil Nadu Open Places (Prevention of Disfigurement) Act, which is also pending at the stage of FIR.

5.This Court considered the rival submission made.

6.It appears that the cases pending against the petitioner is that of the year 2015 and 2022. Other two cases have been ended in acquittal. It appears that the petitioner has not involved in any crime after the year 2022. The other case in Crime No.47 of 2024 is also only for the offence under Section 4A(1b) of Tamil Nadu Open Places (Prevention of Disfigurement) Act.

7.Therefore, this Court directs the respondent police to consider the case of the petitioner and take a decision whether the history sheet is required or not. As per PSO-748, the history sheets opened have to be reviewed periodically, after two years of opening the history sheet and thereafter, annually. However it appears that in the petitioner's case, it has not been reviewed. Therefore, the respondent police is directed to review the history sheet pending against the petitioner, within a period of four weeks, from the date of receipt of a copy of this order.

8.With the above directions, the writ petition stands disposed of.

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