Speedy trial rights can justify quashing a long-pending prosecution when delay is prolonged and unexplained.

Prolonged and unexplained delay in a criminal income-tax prosecution can justify quashing where it infringes the accused's right to a speedy trial under Article 21. The Delhi HC applied a balancing approach to the attendant circumstances and found that the complaint had remained pending for over 19 years, with no satisfactory explanation for the delay in examining the remaining witnesses. On that basis, the Court exercised its constitutional and inherent jurisdiction to terminate the prosecution, subject to deposit of costs, because continuation of the trial would be unjust in the circumstances.

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Issues: Whether the complaint prosecution deserved to be quashed on account of inordinate delay causing infringement of the right to speedy trial.

Analysis: The petition invoked the supervisory and inherent jurisdiction of the Court to set aside the orders below and quash the income-tax complaint. The prosecution had remained pending for over 19 years, and no satisfactory explanation was offered for the delay in examining the remaining witnesses. Applying the principle that the right to speedy trial is part of Article 21 and that each case requires a balancing of all attendant circumstances, the Court found the prolonged and unexplained delay to be a sufficient ground to terminate the prosecution.

Conclusion: The complaint was quashed in favour of the petitioner, subject to deposit of costs as directed.

Final Conclusion: The Court exercised its constitutional and inherent powers to bring the delayed prosecution to an end on the ground that continuation of the trial would be unjust in the circumstances.

Ratio Decidendi: Where criminal prosecution is subjected to prolonged and unexplained delay that infringes the accused's right to a speedy trial, the proceedings may be quashed in exercise of constitutional and inherent jurisdiction, unless continuation is required in the interests of justice.

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