In Anna Waman Bhalerao vs. State of Maharashtra (2025), Supreme Court's Division Bench of Justices J.B. Pardiwala and H. Mahadevan delivered a 28-page long judgement dated September 12, 2025 concluded:"Applications concerning personal liberty cannot be kept pending for years while the applicants remain under a cloud of uncertainty. The consistent line of authority of this Court makes it abundantly clear that bail and anticipatory applications must be decided expeditiously on their own merits, without relegating the parties to a state of indefinite pendency. Prolonged delay in disposal not only frustrates the object of Code of Criminal Procedure, but also amounts to a denial of justice, contrary to the constitutional ethos reflected in Articles 14 and 21." The judgment was authored by Justice Mahadevan. 

Supreme Court issued the following directions:

a) High Courts shall ensure that applications for bail and anticipatory bail pending before them or before the subordinate courts under their jurisdiction are disposed of expeditiously, preferably within a period of two months from the date of filing, except in cases where delay is attributable to the parties themselves.

b) High Courts shall issue necessary administrative directions to subordinate courts to prioritise matters involving personal liberty and to avoid indefinite adjournments.

c) Investigating agencies are expected to conclude investigations in long pending cases with promptitude so that neither the complainant nor the accused suffers prejudice on account of undue delay.

d) Being the highest constitutional fora in the States, High Courts must devise suitable mechanisms and procedures to avoid accumulation of pending bail/anticipatory bail applications and ensure that the liberty of citizens is not left in abeyance. In particular, bail and anticipatory bail applications shall  not be kept pending for long durations without passing orders either way, as such pendency directly impinges upon the fundamental right to liberty.

The judgment reads: "18.1. The Registrar (Judicial) of this Court shall circulate a copy of this judgment to all High Courts for immediate compliance and prompt administrative action."

19. In fine, both appeals fail, and the impugned judgment of the High Court

rejecting the anticipatory bail applications is affirmed. However, we clarify that

the appellants shall be at liberty to apply for regular bail before the competent

court, and if such an application is made, it shall be considered on its own merits,

uninfluenced by any observations made by the High Court or by this Court in

these appeals.