The Delhi High Court on December 10, 2025, dealt with two connected applications in a criminal matter filed by Dheeraj Arora, addressing both a factual clarification in an earlier order and a request for waiver of costs imposed for seeking adjournment. Justice Neena Bansal Krishna passed a detailed order, briefly reflecting on the growing culture of adjournments in courts while granting relief to the petitioner.
Background of the Case
The proceedings arose out of CRL.M.C. 2318/2021, where Dheeraj Arora is the petitioner and Pariney Khanna is the respondent. Earlier, on July 8, 2025, the High Court had passed an order imposing a cost of ₹20,000 due to non-appearance of counsel.
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Subsequently, the petitioner moved two applications. The first sought modification or clarification of the July order, stating that it incorrectly mentioned that the cost had been imposed by the Additional Sessions Judge at Tis Hazari Courts, whereas it was actually imposed by the High Court itself.
During the hearing, the petitioner pointed out the factual error in the earlier order. The application, filed under Section 362 of the Criminal Procedure Code and the corresponding provision under the Bharatiya Nagarik Suraksha Sanhita, requested a simple correction to avoid confusion on record.
Accepting the submission, the court clarified that the cost of ₹20,000 was indeed imposed by the Delhi High Court and not by the trial court. The application was allowed without objection.
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The second application sought waiver of the ₹20,000 cost imposed earlier. Counsel for the petitioner explained that she could not appear on the scheduled date because she was engaged in a time-bound matter before Tis Hazari Courts. It was also argued that she faced personal challenges, being a single mother with two children, and requested the court to take a lenient view.
Justice Neena Bansal Krishna took note of a broader issue affecting the judicial system. The court remarked on what it described as a growing “culture of adjournments” and the misplaced expectation that adjournments would be granted routinely.
“The adjournments have been sought indiscriminately, with no regard to the other counsel or to the time of the Court,” the bench observed, expressing concern over professional discipline. The court also noted that the absence was due to professional engagement rather than personal difficulty, a distinction it said was important.
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Final Decision of the Court
Despite its strong observations, the High Court ultimately decided to waive the cost of ₹20,000. The bench stated that while such conduct was “least appreciated,” it hoped that the practice of casually seeking adjournments would change over time.
Both applications were allowed and disposed of accordingly, bringing the matter to a close on December 10, 2025.
Case Title: Dheeraj Arora v. Pariney Khanna
Case No.: CRL.M.C. 2318/2021
Case Type: Criminal Miscellaneous Case
Decision Date: December 10, 2025















