In 1911 only four provinces in British India were possessed of High Courts of Judicature. Charters to establish High Courts for Bengal, Madras, and Bombay were issued in 1862 and another for the creation of a High Court at Allahabad was issued in 1865. Their Letters Patent were similar in all important respects save that in the case of the High Court at Allahabad no provision was made for the exercise of ordinary original jurisdiction except as regards criminal proceedings against European British subjects. A Chief Court was established for the Punjab in 1866, constituted on the line of Allahabad High Court, but deriving its authority from the Indian Legislature and composed of judges appointed by the Governor –General in Council. Another was created for lower Burma at Rangoon, on the model of presidency High Courts, with original civil and criminal jurisdiction for Rangoon. In all the remaining provinces the highest tribunal was that of the Judicial Commissioner appointed by the Government of India. The Indian High Courts Act 1911 provided for the establishment, if necessary, of additional High Courts in any part of the British India, and in order to meet the needs of the increasing volume of judicial business raised the maximum number if judges from 16 to 20. A provision was also made for the appointment of temporary additional judges by the Governor-General in Council. In exercise of the powers conferred by the Act a High Court was established at Patna in 1915, and another at Lahore in 1919.
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