Jaipur/Udaipur: The Rajasthan High Court has held that the mere registration of multiple criminal cases against a person cannot justify continued police surveillance or retention of a history-sheet unless authorities make a reasoned assessment of the allegations, their outcomes, how recent the cases are and other relevant circumstances. A single-judge bench of Justice Sunil Beniwal directed the Superintendent of Police, Udaipur, to reconsider the continuance of the history-sheet opened against petitioner Naresh Prajapat.
Source: Times of India, Jaipur
Prajapat had 12 criminal cases registered against him between 1996 and 2025, but had suffered only one conviction, nearly three decades ago, Live Law reported. He had approached the court seeking quashing of the history-sheet, which CourtBook reported was opened by an order of the Udaipur SP dated April 1, 2025. His counsel Deepak Menaria argued that the authorities had failed to consider the nature of the cases registered against him and their outcomes, and that mere registration, without examining the allegations and subsequent developments, could not justify opening or continuing a history-sheet.
Source: Live Law
The court observed: 'The number of cases registered against the petitioner, by itself, cannot be determinative, rather the nature of the allegations, the outcome and present status of the criminal proceedings, the recency of the cases and the material bearing upon the petitioner's alleged habitual criminal activity are all relevant considerations.' It added that the number of cases cannot be treated as a substitute for a lawful and reasoned exercise of discretion.
Source: CourtBook
At the same time, the court clarified that conviction is not a mandatory prerequisite for opening a history-sheet under the Rajasthan Police Rules, 1965 — it examined Rules 4.4 and 4.9 — but the competent authority must have reasonable grounds to believe the person falls within the categories prescribed under the rules. The state had opposed the petition, submitting that the 12 cases involved serious offences and that opening a history-sheet did not depend solely on conviction.
Source: Live Law
The court remitted the matter to the Udaipur SP for fresh consideration. The SP must examine Prajapat's criminal antecedents, the outcome and present status of the cases, the material on record and the justification for continuing the history-sheet and surveillance entry, and pass a reasoned order after due application of mind. Prajapat was permitted to submit a representation with supporting documents within two weeks, and the petition was disposed of.