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Issues: Whether a criminal trial can be closed and the accused acquitted merely because the proceedings have continued for a long time and the trial has allegedly become delayed.
Analysis: The right to speedy trial is part of Article 21 of the Constitution of India, but it does not authorise courts to prescribe a rigid outer time-limit for conclusion of criminal trials. The controlling principle is a case-specific balancing of relevant factors, including the nature of the offence, the cause of delay, the conduct of the accused, and whether actual prejudice has been shown. Delay by itself does not justify termination of the prosecution, and the proper course is for the trial court to use the procedural powers available under the Code of Criminal Procedure, 1973 to secure an expeditious trial. Earlier directions treating lapse of time as a mandatory ground for acquittal or discharge were not good law.
Conclusion: The acquittal based solely on delay could not be sustained; the trial was required to be revived and proceeded with expeditiously.
Ratio Decidendi: The right to speedy trial does not permit a court to fix an inflexible outer limit for criminal proceedings or to terminate them automatically on the mere lapse of time; delay must be assessed contextually, and only demonstrated oppression and actual prejudice can justify corrective relief.