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of <h1>Supreme Court Upholds Right to Speedy Trial, Allows Discretion in Delays</h1> <h3>State of Rajasthan Versus Ikbal Hussen</h3> State of Rajasthan Versus Ikbal Hussen - TMI Issues Involved:1. Legality of trial continuation under IPC sections 279, 337, 338, and 304(A).2. Consideration of previous judgments regarding trial limitations.3. Application of Article 21 and right to speedy trial.4. Constitutionality of time limits in criminal proceedings.5. Factors affecting delay in trials and their impact.6. Relevance of demand for speedy trial by the accused.7. Core concerns of the right to speedy trial.8. Revival of trial proceedings and day-to-day basis consideration.Analysis:1. The Supreme Court addressed the issue of the legality of continuing a trial under IPC sections 279, 337, 338, and 304(A) in a case where the trial court directed acquittal due to the prolonged duration of the trial, which was challenged by the State of Rajasthan. The High Court had supported the trial court's decision, emphasizing that trials cannot proceed indefinitely, leading to the closure of evidence and acquittal.2. The Court delved into the examination of previous judgments, particularly the decisions in Raj Deo Sharma cases and 'Common Cause' vs. Union of India cases. The Court referred to the P. Ramachandra Rao case, where it was concluded that setting specific periods of limitation for criminal trials beyond which they must be closed and the accused acquitted is not legally binding. The Court emphasized that the right to speedy trial under Article 21 provides adequate guidelines without the need for rigid time limits.3. In analyzing the application of Article 21 and the right to speedy trial, the Court reaffirmed the principles laid down in the A.R. Antulay case, highlighting that the right to speedy trial is a fundamental aspect of justice. The Court emphasized that the guidelines for speedy trials are not exhaustive and must be applied based on the circumstances of each case, with no fixed outer limit for concluding criminal proceedings.4. The Court examined the constitutionality of time limits in criminal proceedings, emphasizing that the time limits prescribed in previous judgments cannot be treated as mandatory bars for continuing trials. The Court highlighted that criminal courts have the discretion to consider delays on a case-by-case basis and are not obligated to terminate proceedings solely due to the passage of time.5. Factors affecting delay in trials and their impact were thoroughly discussed by the Court. The judgment highlighted that certain delays, such as court congestion or actions by the accused, should be disregarded in assessing the denial of a speedy trial. The Court emphasized the importance of balancing various factors in each case to determine the impact of delays on the trial process.6. The Court emphasized the relevance of the accused's demand for a speedy trial, stating that an accused cannot complain about delays if they did not actively seek an expeditious trial. The judgment underscored the need for the accused to rigorously demand a speedy trial to raise valid concerns about delays in the proceedings.7. Core concerns of the right to speedy trial were outlined, focusing on the protection against incarceration and the impairment of liberty. The Court clarified that the right to speedy trial does not shield the accused from all prejudicial effects of delays but primarily aims to prevent prolonged incarceration without a fair trial.8. Finally, the Court ordered the revival of the trial proceedings, emphasizing that the trial court should consider the matter on a day-to-day basis to adhere to the provisions of Section 309 of the Code of Criminal Procedure, ensuring expeditious progress in the trial.In conclusion, the Supreme Court's judgment provided a comprehensive analysis of the issues related to the legality of trial continuation, the right to speedy trial under Article 21, and the constitutionality of time limits in criminal proceedings, emphasizing the need for a case-specific approach to address delays and ensure a fair trial process.
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