Maharaja Ranjit Singh (1780–1839) is primarily remembered for the powerful Sikh empire he built in Punjab. Far fewer studies, however, have examined the organisation of justice under his rule. Although scholars have evaluated the Maharaja’s economic policies, military strategies and political alliances, they have rarely analysed critically the system of justice he established. This paper attempts a historical analysis of the system of justice and the adjudication processes that prevailed in Punjab under the sovereign rule of Maharaja Ranjit Singh. It critically evaluates the sources and methods used by British colonial writers such as Lepel Griffin, W.G. Osborne and J.D. Cunningham, and by Indian historians such as Narendra Krishna Sinha, Khushwant Singh and Lochan Singh Buxi, among others. From these accounts it assesses the organisation, procedures and practices of the courts that operated under Ranjit Singh’s administration. It also examines how justice was administered in rural society and the various laws prevailing in the region, and discusses the strengths and weaknesses of the court system and its procedures. Finally, it draws conclusions on the relevance of the Maharaja’s judicial practices to judicial reform in contemporary India.
A brief review of the literature follows.
• Colonial historians: Cunningham (1849) treats Ranjit Singh’s rule within a general history of the Sikhs,1 and Griffin (1892) offers a biographical sketch of the Maharaja and his court.2
• European travellers: Burnes (1834) recorded that the Maharaja had never punished a criminal with death since his accession,3 while Osborne (1840) described summary trials and mutilation.4
• Indian historians: Sinha (first published 1933) records that fines were levied in almost all cases, that imprisonment was unknown and that there was no written law;5 Khushwant Singh (1962) details the hierarchy of courts from the panchayat to the Durbar and the plurality of laws.6
• Contemporary issues: The National Judicial Data Grid tracks case pendency and promotes transparency. The Department of Justice’s Year-End Review (2025) describes Tele-Law, Fast Track Courts and related initiatives, and the paper also draws on other government reports and newspaper articles.
• To study the structure and hierarchy of judicial administration in the territories ruled by Maharaja Ranjit Singh.
• To study the principles of justice under Maharaja Ranjit Singh, including access to justice, punishment and legal pluralism.
• To analyse the role of village panchayats, religion-based customary laws and religious courts in the judicial system.
• To discuss the limitations and challenges of the judicial system.
• To draw comparatively on this historical record for modern judicial reform in India.
This study follows a qualitative historical method. It uses primary sources, including colonial records and travellers’ accounts, together with secondary works by N.K. Sinha, Khushwant Singh, L.S. Buxi, J.D. Cunningham and Lepel Griffin. Data collection involves archival research and textual analysis. The judicial system is studied thematically, covering its structure, principles, pluralism and limitations, and is interpreted critically in its historical context. The comparative analysis draws on the National Judicial Data Grid and government reports. The approach is descriptive, analytical and interpretive.
The judicial system in the time of Maharaja Ranjit Singh was decentralised and based on community participation. It sought to make justice easy to access, allowed different legal traditions to coexist, and emphasised redress over punishment. These ideas of accessibility, legal pluralism and restorative justice remain important today and can guide efforts to improve the judicial system in India; the values of that era continue to be relevant to reform.
The judicial system of the Sikh Empire was hierarchical yet decentralised, with several levels of justice operating simultaneously. The Maharaja himself stood at its apex. As Chhabra records, “The fountain-head of justice was in the King himself, who heard appeals above the highest court of the State and intervened to see that justice in a court was properly dispensed.”7 Khushwant Singh records that any person who had failed to get justice could present a petition at the palace gates or to the Maharaja on tour, and that Ranjit Singh “disposed of such petitions summarily or passed them on to one of his ministers”.8
1. The Adalat-i-Ala (Central Court) was the highest judicial authority after the Maharaja. Situated at Lahore, it heard appeals from the courts of the nazims and kardars before they went to the King himself. Special adalti courts were established in Amritsar and Peshawar, which decided civil and criminal cases arising within those cities. The nazim’s court was the highest court in a province, with mainly appellate authority over the court of the kardar, who headed each district.9 Of the cases dealt with by the Maharaja himself, Osborne wrote: “His executions are very prompt and simple, and follow quickly on the sentence: one blow of an axe, and then some boiling oil to immerse the stump in, and stop all effusion of blood, is all the machinery he requires for his courts of justice. He is himself accuser, judge, and jury; and five minutes is about the duration of the longest trial at Lahore.”10
2. Religious courts: The state maintained separate courts for different religious communities. Qazi Nizamuddin was appointed to decide marital issues among Muslims, while the Muftis Mohammad Shahpuri and Saidullah Chishti were entrusted with powers to draw up title deeds relating to transfers of immovable property.11 To safeguard Islamic traditions, Ranjit Singh “brought the various Muslim sects into one organization and made Kazi Nizamuddin the head of this organization”.12
3. Jagirdari courts: The jagirdars had extensive judicial powers in civil and criminal matters. As Chhabra notes, there were “the Jagirdari courts held by Jagirdars, whether Hindu, Muslim or Sikh, which enjoyed autocratic rights within their jurisdiction, both civil and criminal, and ordinarily the subjects of the Jagirdars could not bring their appeals to the regular courts of the State”.13
4. Village panchayats: The village panchayat was the primary judicial tribunal of rural Punjab. Khushwant Singh describes the village panchayat, a “council of five elders”, as “the primary and the most important tribunal”.14
The panchayat system operated on principles of community participation and local knowledge:
• Composition: five elders respected in the community.
• Jurisdiction: civil, revenue, matrimonial and criminal cases.
• Appeals: to the kardar or, in the larger towns, to the nazim.15
• Limits: justice was left to local authorities, and, as Sinha observes of the local feudatories, “as they were men of the locality they could not go far”.16
Sinha also notes that “[t]he village communities were left undisturbed in the enjoyment of their ancestral rights”,17 and that “[j]ustice was not so much a national as a local concern. It was left to the feudatories but as they were men of the locality they could not go far.”18
The penal system of the Sikh Empire under Maharaja Ranjit Singh was notable for its avoidance of capital punishment and its emphasis on economic penalties. Osborne described the Maharaja’s executions of sentence as “very prompt and simple”;19 the punishments he recorded, however, were mutilations rather than sentences of death.
The evidence indicates that capital punishment was virtually unknown in the Sikh Empire, except at frontier places such as Peshawar.20 Buxi quotes Captain Fane’s account that the Maharaja “never awarded death penalty to anyone, however dastardly the crime”.21 Sinha is more guarded, recording that “capital punishments were rare”.22 This was a notable departure from the practice of contemporary states, and the Maharaja’s reluctance to impose the death penalty may reflect Sikh principles of compassion and the belief in the sanctity of life.
In the most serious cases “parts of a criminal’s body were chopped off”.23 Osborne describes the method.24 Corporal punishment was nevertheless not the rule: as Chhabra notes, “imprisonment was rarely resorted to” and “there was hardly a punishment which could not be commuted to fine”.25 Osborne records one summary case: “During our sojourn at Adeenanuggur, an individual, supposed to be a servant of Rajah Golaub Sing’s, was detected by one of the sentries concealed in a mango tree, overlooking Runjeet’s Zenana. . . . [H]e was sent for by the Maharajah, and in five minutes dismissed without either ears or nose, and died in a few hours.”26
The most common form of punishment was a fine, known as jurmana. In Sinha’s account, “[f]ines were levied in almost all cases”.27 The judicial system was, in effect, also a source of revenue; in Chhabra’s words, “[j]ustice was essentially a source of income”.28 Several types of economic penalty existed:
1. Jurmana (fine): the losing party paid a fine. In Chhabra’s account, “the losing as well as the winning parties had to pay. The former paid as a Jurmana or fine.”
2. Nazrana (complimentary gift): the winning party paid nazrana “for the favour of the case having been decided in its favour”, in recognition of the judge’s authority.
3. Taikhana (time-waste fee): if a case was prolonged, “the victim party had to pay a special amount known as Taikhana for the waste of the judge’s time”, a levy evidently meant to discourage protracted proceedings.
4. Shukrana (thank-offering): on the recovery of stolen goods, one-fourth of them was given to the judge as Shukrana, a reward for the judge’s efforts in recovering the property and doing justice.29
Imprisonment was used very little. Chhabra notes that “imprisonment was rarely resorted to”.30 Khushwant Singh records that gaols “were usually maintained only for political prisoners”.31 Forts such as Govindgarh and Mankera served as state prisons.
Ranjit Singh’s judicial system rested on the principle of equality. A Persian decree dated 31 Bhadra, 1882 of the Vikrama era (1825), issued in the name of Nur Din, the Home Minister, stated: “No one must subject anyone to any kind of coercion and no excesses should be committed against anyone. If any order issued by the Maharaja’s government is found to be unjust, it should immediately be brought to the notice of the authorities so that it can be amended. . . . All court decisions must carry the sanction of equity. Those with just claims should be given their due in full. Rulings should be based on the advice of the Panchs and the Kazis and should show due respect to the traditions and tenets of the parties in the dispute.”32
Justice was swift and decisive. Osborne observed that the Maharaja’s “executions are very prompt and simple, and follow quickly on the sentence”, and that “five minutes is about the duration of the longest trial at Lahore”.33
Legal pluralism was one of the outstanding features of Ranjit Singh’s judicial administration. The state did not apply a single body of law but recognised several legal traditions. In Khushwant Singh’s words, “The Punjab had no codified law – except to the extent that the Shariat could be described as a code for the Muslims. But all Punjabis (including Muslims) were governed by well-recognized custom.”34 Muslims had their own courts to administer the Shariat: “Nizam Din was appointed Chief Kazi (Judge) with Mohammed Shahpuri and Saidullah Chishti as the two Muftis.”35 For Hindus and Sikhs, the customary laws of the locality were administered by local tribunals. “Custom and caprice were the substitutes for legal codes”, and “[t]he Qazis and Qanungos exercised privately and indirectly those functions which had descended to them since the Imperial times”.36
The system recognised multiple legal traditions:
• Islamic law (Shariat): administered by Qazis and Muftis for Muslims.
• Hindu customary law: applied to Hindus by their own authorities.
• Sikh usage: Sikhs were governed by Sikh tradition and local custom.37
• Local custom: the primary source of law for most Punjabis.38
Customary law was followed in substance as well: in Khushwant Singh’s account, the tribunals that administered it “heard all kinds of cases: civil, revenue, matrimonial and criminal”, and “[c]rime was punished by well-understood and generally accepted penalties”.39
The Maharaja showed respect to religious authorities: he “maintained the established Muslim tradition of State-grants to Ulemas and holymen” and “paid great attention to the Muslim relics”, and Sinha judges that he “was superior to communal prejudices”.40 This pluralistic approach helped to secure justice according to the customs and usages of the various communities, although it meant that the law was not uniform.
The recognition of Shariat, Hindu, Sikh and customary laws by a single sovereign in the nineteenth century is an outstanding experiment in legal pluralism, with contemporary relevance to questions of personal law and minority rights in modern India. The well-known historian Syed Wahiduddin, as quoted by Buxi, recorded: “Ranjit Singh followed the policy of allowing the fullest freedom to everybody to follow the ways of his own faith. During his rule there was goodwill between the followers of different faiths and perfect religious amity.”41
Despite its strengths, the judicial system under Ranjit Singh had its limitations. Sinha points out: “There were no special officers for the dispensation of civil justice or for the execution of criminal law. The chiefs generally judged both civil and criminal cases and thus no regular courts of law were required. There was no written law.”42
Other limitations include the following:
• Absence of codified law: “The Punjab had no codified law – except to the extent that the Shariat could be described as a code for the Muslims.”43
• Crudeness of punishment: “Justice was crude – but it was cheap, expeditious and in conformity with tradition.”44
• Regional variation: “In distant and disturbed provinces like Peshawar and Hazara, however, the case was different.”45
• Corporal punishment: “Violence and theft were punished with a fine or corporal punishment, frequently by the cutting of the nose, ears or hands.”46
• Martial law in frontier regions: “except where the Nazim enforced martial law (as Avitabile did on the North-West Frontier)”.47
These limitations were compounded, as Sinha concedes: “Many defects there were undoubtedly in Ranjit’s judicial administration and police system.”48
The judicial system of Maharaja Ranjit Singh can be seen as a source of inspiration and guidance for today’s reforms towards decentralisation in India.
Decentralised justice: The panchayat system of that era, which resolved conflicts at the village level, can serve as a model for contemporary debates on alternative dispute resolution and access to justice. Sinha’s observation that “[j]ustice was not so much a national as a local concern” supports the point.49 The same idea underlies the Gram Nyayalayas Act, 2008.50
Legal pluralism: The recognition of multiple legal traditions, Islamic, Hindu, Sikh and others, and the respect accorded to them under one sovereign can inspire legal pluralism in a modern society. The organisation of separate courts for Muslims and the application of religious laws can be related to today’s debates on personal laws and minority rights.
Accessibility: The right of every individual to approach the Maharaja with the cry “dohai, Maharajah, dohai”51 can be related to modern Lok Adalats, legal aid and other initiatives to provide justice for all.
Restorative justice: The preference for fines over imprisonment and the absence of the death penalty can be related to modern moves to replace imprisonment with monetary penalties for minor offences, such as the Jan Vishwas (Amendment of Provisions) Act, 2023.52 Buxi, moreover, records Khushwant Singh’s view that “in the history of the entire world it would be difficult to find a ruler who never took a life and yet carved such a magnificent kingdom”.53
Codification: Ranjit Singh’s appointment of Bahadur Singh Hindustani in 1828 “to prepare a Civil and a Criminal Code”54 can be related to the later codification of the Indian Penal Code and the Code of Civil Procedure in British India.
Community participation: The panchayat’s role as an institution of local self-government can be related to modern Panchayati Raj.55
On the other hand, the weaknesses of the system also bear on some issues in India’s modern judicial system. Largely uncodified law, severe but primitive punishments, and wide regional variation are among the reasons it was eventually replaced. The contemporary task is to recognise the positive features of the former system and build them into current reforms while overcoming its weaknesses.
The judicial system of India needs reform. According to the National Judicial Data Grid (NJDG), as on 9 March 2026, 92,755 cases were pending in the Supreme Court and 63,61,340 in the twenty-five High Courts,56 while 4,95,49,089 cases were pending in the subordinate courts.57 Replying in the Rajya Sabha, the Minister of State (Independent Charge) for Law and Justice, Arjun Ram Meghwal, said: “The Central Government is committed for speedy disposal of cases and reducing pendency as mandated under Article 21 of the Constitution and has taken several initiatives to provide an ecosystem for faster disposal of cases by the judiciary.”58 Pendency on this scale produces a chronic judicial backlog.
Undertrials make up about three-quarters of India’s prison population. At the end of 2023 India had some 5.3 lakh people in jail, of whom about 3.9 lakh, or 74 per cent, had not been convicted of any offence by a court of law.59 The proportion is much the same as it was two decades ago: the National Human Rights Commission put it at 74.06 per cent as of 30 June 2002.60 “Delays in investigations, a severe shortage of judges (21 per million), and limited legal aid are key contributors to this persistent issue. Consequently, jails remain critically overcrowded at 121% occupancy,” the Times of India noted in its analysis of the latest NCRB data.61 The judge-to-population ratio stands at about 21 judges per million population,62 less than half the 50 judges per million recommended by the Law Commission in its 120th Report.63
| As on | Total inmates | Undertrial inmates | Undertrials as a share of inmates | Prison occupancy |
|---|---|---|---|---|
| 30 June 200264 | 3,04,893 | 2,25,817 | 74.06% | 131.19% |
| End of 202365 | 5,30,333 | 3,89,910 | 73.5% | 121% |
Table 1: Undertrial prisoners and prison occupancy in India, 2002 and 2023. Sources: National Human Rights Commission (2002); National Crime Records Bureau prison statistics for 2023, as reported in the Times of India. Occupancy is the number of inmates as a share of authorised capacity.
The Gram Nyayalayas Act, 2008 was passed “for the establishment of Gram Nyayalayas at the grass roots level for the purposes of providing access to justice to the citizens at their doorsteps”.66 Implementation has been poor. According to the Department of Justice dashboard, 489 Gram Nyayalayas have been notified across fifteen States and Union Territories, but only 338 are operational, in eleven States.67 Punjab, ironically the land of Ranjit Singh’s panchayat system, has notified nine Gram Nyayalayas, of which only two are functional.68
| Dimension | Modern India | Ranjit Singh’s Punjab |
|---|---|---|
| Pendency | About 5.6 crore cases pending in the Supreme Court, the High Courts and the subordinate courts as on 9 March 2026 (National Judicial Data Grid)69 | No recorded backlog; a trial before the Maharaja lasted about “five minutes”70, with the panchayat and the courts of the kardar and the nazim below him |
| Undertrials | 74% of prisoners are undertrials; jails at 121% occupancy71 | Imprisonment was “unknown”; fines were the norm72 |
| Grassroots courts | Only 338 Gram Nyayalayas operational, in eleven States (Department of Justice dashboard)73 | The panchayat was “the primary and the most important tribunal”74 |
| Judge–population ratio | About 21 judges per million population (Lok Sabha Unstarred Question No. 1335, answered 9 February 2024)75 | Local elders and kardars resolved disputes at the community level |
| Access to justice | Litigants approach the formal courts (district courts, and writ petitions in the High Courts and the Supreme Court), which are expensive and slow; Article 39A of the Constitution directs the State to provide free legal aid76 | Any person could cry “dohai, Maharajah, dohai” at the palace gates77 |
| Punishment philosophy | Imprisonment, graded by the nature of the offence under the various civil and criminal laws | Fines were “levied in almost all cases”78 |
Table 2: Justice in modern India and in Ranjit Singh’s Punjab compared
Ranjit Singh’s judicial system was not perfect: it lacked codified law, relied on corporal punishment and varied by region. Its core strengths, however, namely local resolution, community participation and accessible authority, offer valuable lessons for contemporary India. The panchayat system’s emphasis on decentralised justice prefigures the Gram Nyayalayas, whose poor implementation is a missed opportunity to reduce long-standing pendency. The historical preference for fines over imprisonment speaks to modern debates on decriminalisation and restorative justice, as opposed to physical and capital punishment; the Government has, for instance, decriminalised a range of minor offences through the Jan Vishwas (Amendment of Provisions) Act, 2023.79 The accessibility of the Maharaja’s Durbar, where any subject could petition directly, finds a modern reflection in the National Judicial Data Grid’s goal of transparency and in the Tele-Law initiative’s reach to grassroots populations. The challenge for contemporary India is to revive the spirit of decentralised, participatory justice while addressing the historical limitations of codification, uniform rights and due process.
The judicial system of Maharaja Ranjit Singh is an integral and underestimated part of Sikh and Indian legal history. This study has examined its historical setting, structure, principles and philosophy, as well as its limitations and present-day relevance. The system was hierarchical yet decentralised: the panchayat was “the primary and the most important tribunal”, the kardar and the nazim heard appeals, and the Maharajah and his Durbar “acted as the Supreme Court”.80 It was marked by legal pluralism, with law applied according to religious affiliation: the Shariat for Muslims, administered by the Qazis and Muftis, and customary law for Hindus and Sikhs, adjudicated by the elders.81 In addition, justice at Lahore was accessible to every subject, who could call on the King for redress.
Nevertheless, the system had significant limitations, including the lack of consistent written law, physical punishment, regional variation and the absence of enforceable rights for subjects. In Sinha’s words, “Custom and caprice were the substitutes for legal codes.”82
The present Indian judicial system may yet learn from Ranjit Singh’s. India today struggles with a very large number of pending cases, a high proportion of undertrials (74 per cent of all prisoners) and few working Gram Nyayalayas (338 operational, in eleven States). The National Judicial Data Grid, Tele-Law and Lok Adalats have been introduced to address some of these problems.
Research on the judicial system of Ranjit Singh, a celebrated yet controversial historical figure, inevitably raises questions about the values and philosophy on which that system was built. This paper shows that, although the system was imperfect and its fees and fines could bear heavily on the poor, it was innovative and efficient. It can also be described as progressive in its legal pluralism, restorative approach and accessibility. These values and ideas could be incorporated into the modern judicial system to make it more efficient and humane.
The following recommendations draw on the comparison above.
1. Strengthen decentralised panchayat courts: Ranjit Singh’s panchayat was “the primary and the most important tribunal”.83 Modern India should strengthen the Gram Nyayalayas, of which only 338 are operational, in eleven States. Village-level courts can reduce pendency and bring justice to people’s doorsteps. The State and the judiciary should support the functioning of Gram Nyayalayas with administrative and financial assistance.
2. Adopt restorative justice over imprisonment: As Burnes wrote, in a passage quoted by Khushwant Singh, “The most creditable trait in Ranjit’s character is his humanity; he has never been known to punish a criminal with death since his accession to power . . . cunning and conciliation have been the two great weapons of his diplomacy.”84 Today 74 per cent of prisoners are undertrials. Minor offences should be decriminalised, community service expanded and fines used to reduce overcrowding (121 per cent occupancy).
3. Ensure direct access to justice: The historical cry “dohai, Maharajah, dohai” (mercy, Maharajah, mercy) allowed any subject to petition the sovereign.85 Its modern equivalents include Tele-Law, alternative dispute resolution and eCourts. The Government and the judiciary should expand digital platforms so that litigants and victims can seek remedies without needing a lawyer.
4. Strengthen Lok Adalats and ADR: Ranjit Singh’s system relied on community mediation and local custom.86 Lok Adalats should be scaled up nationwide as a forum for pre-litigation mediation, given greater authority in civil cases, and directed to focus first on mediation between the parties rather than on the filing of suits. Strengthening ADR mechanisms in this way would reduce the burden on the courts, and tribunals could be established for specialised cases.
5. Balance legal pluralism with constitutional rights: Ranjit Singh recognised Shariat, Hindu, Sikh and customary laws.87 Modern India must respect personal laws while subjecting them to equality, dignity and due process. A consultative review every decade could help avoid arbitrary uniformity across religious groups.
This study has several limitations. First, it relies heavily on secondary sources and translated primary sources; original Persian and Gurmukhi records remain largely inaccessible. Second, the colonial accounts of Cunningham, Griffin and the European travellers are shaped by imperial perspectives and may exaggerate or omit details. Third, although a few studies exist on Ranjit Singh’s administration, none treats the judicial system at length, so this study synthesises scattered references from broader works. Fourth, the comparison with contemporary reforms is illustrative rather than empirical, lacking field data or statistical testing. Finally, the study focuses on Punjab under Ranjit Singh and excludes other Indian regions, which limits its generalisability. These limitations do not, however, undermine the study’s exploratory and historical value.
*****
1. J.D. Cunningham, A History of the Sikhs from the Origin of the Nation to the Battles of the Sutlej (H.L.O. Garrett ed., rev. ed. 1918) (1849).
2. Lepel Griffin, Ranjit Singh (Oxford, Clarendon Press 1892).
3. 3 Alexander Burnes, Travels into Bokhara 167 (London, John Murray 1834).
4. W.G. Osborne, The Court and Camp of Runjeet Sing 147, 182 (London, Henry Colburn 1840).
5. Narendra Krishna Sinha, Ranjit Singh 145–46 (2d ed. 1945) (1933).
6. Khushwant Singh, Ranjit Singh: Maharajah of the Punjab 1780–1839 161 (1962).
7. 2 G.S. Chhabra, Advanced Study in the History of Modern India (1813–1919) 132 (2d ed. 1984).
8. Singh, supra note 6, at 161.
9. Chhabra, supra note 7, at 132–33.
10. Osborne, supra note 4, at 182; see also Chhabra, supra note 7, at 133 (quoting the passage and citing Osborne at 67).
11. See Singh, supra note 6, at 48; cf. Sinha, supra note 5, at 146 (recording that the Qazis “continued to ordain marriage ceremonies, to register testaments and attest deeds”).
12. L.S. Buxi, Maharaja Ranjit Singh 11 (Ajit Uniyal trans., 1992).
13. Chhabra, supra note 7, at 133.
14. Singh, supra note 6, at 161.
15. Id.
16. Sinha, supra note 5, at 146.
17. Id. at 139.
18. Id. at 146.
19. Osborne, supra note 4, at 182.
20. Chhabra, supra note 7, at 133.
21. Buxi, supra note 12, at 52 (quoting Henry Edward Fane, Five Years in India).
22. Sinha, supra note 5, at 146.
23. Chhabra, supra note 7, at 133.
24. Osborne, supra note 4, at 182.
25. Chhabra, supra note 7, at 133.
26. Osborne, supra note 4, at 147.
27. Sinha, supra note 5, at 146.
28. Chhabra, supra note 7, at 133.
29. Id.
30. Id.
31. Singh, supra note 6, at 161.
32. Buxi, supra note 12, at 12.
33. Osborne, supra note 4, at 182.
34. Singh, supra note 6, at 161.
35. Id. at 48.
36. Sinha, supra note 5, at 146.
37. Buxi, supra note 12, at 11; Singh, supra note 6, at 161.
38. Singh, supra note 6, at 161.
39. Id.
40. Sinha, supra note 5, at 148; The Panjab in 1839–40: Selections from the Punjab Akhbars, Punjab Intelligence, etc. 5 (Ganda Singh ed., 1952).
41. Buxi, supra note 12, at 12.
42. Sinha, supra note 5, at 145.
43. Singh, supra note 6, at 161.
44. Id.
45. Sinha, supra note 5, at 146.
46. Singh, supra note 6, at 161.
47. Id.
48. Sinha, supra note 5, at 146.
49. Id.
50. The Gram Nyayalayas Act, 2008, No. 4, Acts of Parliament, 2009 (India).
51. Singh, supra note 6, at 161.
52. The Jan Vishwas (Amendment of Provisions) Act, 2023, No. 18, Acts of Parliament, 2023 (India).
53. Buxi, supra note 12, at 52.
54. Singh, supra note 6, at 161 & n.1 (noting that no record of the written code has been found).
55. India Const. art. 40; India Const. pt. IX, arts. 243–243O (inserted by The Constitution (Seventy-third Amendment) Act, 1992). Panchayats under Part IX are units of local self-government rather than courts; adjudication at the village level is provided for by the Gram Nyayalayas Act, supra note 50.
56. Ministry of Law & Justice, Rajya Sabha Unstarred Question No. 3153, Pendency of Cases in Higher Judiciary, annex. I (answered Mar. 19, 2026), in Dep’t of Justice, Rajya Sabha Replies: 2nd Part of Budget Session, 2026, at 53–56, https://www.doj.gov.in/static/uploads/2026/04/b7b4da487543be9a9f1d1558d06d76d2.pdf.
57. Ministry of Law & Justice, Rajya Sabha Unstarred Question No. 2352, Pendency of Cases (answered Mar. 12, 2026), in Rajya Sabha Replies, supra note 56, at 6–9.
58. Id.
59. Atul Thakur, 74% of Prisoners Are Undertrials, and That’s an ‘Improvement’, Times of India (Oct. 4, 2025), https://timesofindia.indiatimes.com/india/74-of-prisoners-are-undertrials-and-thats-an-improvement/amp_articleshow/124298582.cms.
60. Press Release, Nat’l Hum. Rts. Comm’n, Undertrials Constitute 74.06 Per Cent of the Total Prison Population in the Country (data as of June 30, 2002), https://nhrc.nic.in/media/press-release/28 (last visited Oct. 3, 2026).
61. Thakur, supra note 59.
62. Ministry of Law & Justice, Lok Sabha Unstarred Question No. 1335, Number of Judges per Million Population (answered Feb. 9, 2024) (giving the ratio as approximately 21 judges per million population), https://sansad.in/getFile/loksabhaquestions/annex/1715/AU1335.pdf?source=pqals.
63. Law Comm’n of India, Report No. 120, Manpower Planning in Judiciary: A Blueprint (1987).
64. Press Release, Nat’l Hum. Rts. Comm’n, supra note 60 (2,25,817 undertrials in a jail population of 3,04,893 as of June 30, 2002; authorised capacity 2,32,412, an overcrowding of 31.19 per cent).
65. Thakur, supra note 59 (reporting National Crime Records Bureau data for 2023: 5,30,333 inmates, of whom 3,89,910 were undertrials, and prison occupancy of 121 per cent).
66. The Gram Nyayalayas Act, supra note 50, long title.
67. Dep’t of Justice, Notified Gram Nyayalayas, Gram Nyayalaya Dashboard, https://dashboard.doj.gov.in/gn/notified_gram_nyayalaya (last visited Oct. 3, 2026); Dep’t of Justice, Operational Gram Nyayalayas, Gram Nyayalaya Dashboard, https://dashboard.doj.gov.in/gn/operational_gram_nyayalaya (last visited Oct. 3, 2026).
68. Id.
69. Rajya Sabha Unstarred Question No. 3153, supra note 56; Rajya Sabha Unstarred Question No. 2352, supra note 57.
70. Osborne, supra note 4, at 182.
71. Thakur, supra note 59.
72. Sinha, supra note 5, at 146.
73. Dep’t of Justice, Operational Gram Nyayalayas, supra note 67.
74. Singh, supra note 6, at 161.
75. Lok Sabha Unstarred Question No. 1335, supra note 62.
76. India Const. art. 39A.
77. Singh, supra note 6, at 161.
78. Sinha, supra note 5, at 146.
79. The Jan Vishwas (Amendment of Provisions) Act, supra note 52.
80. Singh, supra note 6, at 161.
81. Id. at 48; Sinha, supra note 5, at 146.
82. Sinha, supra note 5, at 146.
83. Singh, supra note 6, at 161.
84. Singh, supra note 6, at 170–71 (quoting Burnes, supra note 3, at 167).
85. Singh, supra note 6, at 161.
86. Sinha, supra note 5, at 146.
87. Singh, supra note 6, at 161.