Speedy trial requires case-by-case balancing; rigid time limits for criminal proceedings are impermissible and A.R. Antulay prevails.

The right to speedy trial under Article 21 was held to require a case-specific balancing of delay, prejudice and overall circumstances; rigid judicially fixed outer time limits for criminal trials were impermissible because they would amount to judicial legislation and automatic termination on expiry was rejected. Earlier directions in Common Cause and Raj Deo Sharma were held not to be good law to the extent they mandated hard time bars, while A.R. Antulay was reaffirmed as the controlling precedent. The Court stated that the prior time periods may only serve as reminders when assessing delay in individual cases, and existing procedural and constitutional remedies remain available against oppressive delay.

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Issues: (i) Whether courts can prescribe rigid outer time limits or bars of limitation for the conclusion of criminal trials and proceedings and compel acquittal or discharge on expiry of such limits. (ii) Whether the earlier directions in the Common Cause and Raj Deo Sharma decisions lay down binding law on speedy trial and whether the Constitution Bench ruling in A.R. Antulay continues to hold the field.

Issue (i): Whether courts can prescribe rigid outer time limits or bars of limitation for the conclusion of criminal trials and proceedings and compel acquittal or discharge on expiry of such limits.

Analysis: The right to speedy trial is part of the guarantee of fair, just and reasonable procedure under Article 21, but its application depends on the facts of each case. The Court held that the relevant enquiry is whether the delay, judged on a balancing of all circumstances, has become oppressive or unwarranted. It emphasised that judicially created hard time limits would amount to legislation, which lies beyond judicial power, and would also cut across the settled approach that delay must be assessed case by case. The Court further stated that existing procedural powers under the criminal law and constitutional remedies remain available to deal with oppressive delay.

Conclusion: Rigid judicially fixed time limits for terminating criminal proceedings were held impermissible, and the right to speedy trial must be enforced by case-specific judicial evaluation rather than automatic expiry rules.

Issue (ii): Whether the earlier directions in the Common Cause and Raj Deo Sharma decisions lay down binding law on speedy trial and whether the Constitution Bench ruling in A.R. Antulay continues to hold the field.

Analysis: The Court held that the earlier directions prescribing mandatory time limits for closure of proceedings were inconsistent with the larger Constitution Bench ruling in A.R. Antulay, which had already rejected the advisability and feasibility of any outer time limit for criminal trials. Applying the doctrine that a smaller Bench cannot depart from a larger Bench, the Court reaffirmed that A.R. Antulay states the correct law. The Court also made clear that the earlier time-limit directions cannot operate as hard and fast rules, though the periods mentioned therein may serve only as reminders for judicial consideration of delay in individual cases.

Conclusion: The earlier time-limit directions were held not to be good law to the extent they mandated automatic termination, and A.R. Antulay was reaffirmed as the controlling precedent.

Final Conclusion: The appeals succeeded, the impugned High Court orders were set aside, and the matters were required to be reconsidered afresh in accordance with the principles laid down by the Court on speedy trial and delay.

Ratio Decidendi: The right to speedy trial under Article 21 is enforceable through a case-specific balancing approach, but courts cannot, by judicial fiat, prescribe rigid outer time limits that automatically terminate criminal proceedings, because such a rule would amount to impermissible judicial legislation and would conflict with binding larger Bench precedent.

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