Speedy investigation and trial under Article 21 can justify quashing criminal proceedings when delay is unexplained and prejudicial.

Unexplained and inordinate delay in criminal investigation and trial can justify quashing proceedings where continuation would amount to abuse of process or defeat the ends of justice. The right to speedy investigation and trial forms part of Article 21, and the court must assess the length and causes of delay, responsibility for delay, the nature of the accusation, and actual prejudice before balancing all circumstances. On the stated facts, the prolonged pendency was not attributable to the accused, no satisfactory explanation was offered, and the trial had not commenced for an extended period, so the constitutional right was held to be violated and the proceedings were quashed.

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Issues: Whether the criminal proceedings were liable to be quashed on the ground that the appellant had been denied the constitutional right to speedy investigation and trial.

Analysis: The Court reiterated that the power to quash criminal proceedings under the inherent jurisdiction must be exercised sparingly, but it may be invoked where continuation of the proceedings would amount to abuse of process or defeat the ends of justice. It also restated that the right to speedy trial is part of Article 21 and extends to investigation as well as trial. In deciding such a plea, the relevant factors include the length of delay, the causes of delay, responsibility for delay, the nature of the accusation, and whether the delay has caused prejudice, with the court required to balance all attendant circumstances. On the facts, the investigation had remained prolonged without any satisfactory explanation, the trial had not commenced for an inordinate period, and the delay was not attributable to the appellant. The Court found that the prolonged pendency and uncertainty had violated the appellant's constitutional protection.

Conclusion: The proceedings were liable to be quashed because the appellant's right to speedy investigation and trial had been infringed.

Ratio Decidendi: Where unexplained and inordinate delay in investigation and trial violates the accused's right under Article 21 and no balancing factor justifies continuation, the criminal proceedings may be quashed in exercise of inherent jurisdiction.

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