Speedy trial under Article 21: unexplained investigative delay can justify quashing of criminal proceedings.

The constitutional right to a speedy investigation and trial under Article 21 extends to the entire criminal process, including investigation, and prejudice must be assessed through a balancing test considering the nature of the offence, responsibility for delay, systemic factors, and surrounding circumstances. Here, the investigation remained stalled for an exceptionally long period despite an earlier direction to complete it within a fixed time, and the delay from December 1990 to February 2007 was wholly unexplained. Because the delay was not attributable to the accused and no exceptional justification was shown, continuation of the criminal proceedings amounted to a violation of the speedy trial guarantee and the proceedings were liable to be quashed.

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Issues: Whether inordinate and unexplained delay in investigation and trial violated the accused's right to speedy trial under Article 21 so as to justify quashing of the criminal proceedings under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The right to speedy investigation and trial is part of the procedure established by law and flows from Article 21 of the Constitution of India. That right extends to the entire criminal process, including investigation, and the court must assess prejudice by applying a balancing test, having regard to the nature of the offence, responsibility for delay, systemic factors, and the surrounding circumstances. On the facts, the investigation remained stalled for an exceptionally long period despite an earlier judicial direction to complete it within a fixed time, and the delay from December 1990 to February 2007 remained wholly unexplained. The delay was not attributable to the accused, and the prosecution failed to show any exceptional circumstance justifying continuation of the proceedings.

Conclusion: The delay amounted to a violation of the constitutional guarantee of speedy investigation and trial, and the criminal proceedings were liable to be quashed in favour of the appellant.

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