A count of cases cannot by itself keep a history sheet open, Rajasthan High Court holds

30 October 2026

The Rajasthan High Court has held that the number of criminal cases against a person cannot by itself justify keeping him under continued police surveillance through a history sheet.
Justice Sunil Beniwal decided Naresh Prajapat v State of Rajasthan, on history sheets opened under the Rajasthan Police Rules, 1965.
The Court held that a conviction is not a precondition for opening a history sheet, and that acquittal, compromise or the absence of conviction does not automatically bar one either.
What the Rules require is that the competent authority have reasonable grounds to believe the person falls within a category the Rules prescribe, and that it apply reasoned discretion.
The authority must weigh the nature and recency of the cases, their outcomes, any later criminal involvement and the material it actually looked at.
The matter was remitted to the Superintendent of Police, Udaipur, to reconsider the history sheet against the petitioner, who had twelve cases with a single conviction about thirty years earlier, four negative final reports, three acquittals and two pending trials.