Right to speedy trial bars decades-long criminal proceedings where delay is unexplained and not attributable to the accused.

The SC reaffirmed that the right to speedy trial is part of Article 21 and applies through investigation, inquiry, trial, appeal, revision and retrial. It held that prolonged and unexplained delay must be assessed on the facts of each case, but where the accused is not at fault and the prosecution has made no meaningful progress for decades, the continuation of proceedings becomes oppressive and unfair. On the facts, no prosecution witness had been examined for more than twenty-six years and the delay was not attributable to the appellant. The criminal proceedings were therefore quashed as a violation of the right to speedy trial and an abuse of process.

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Issues: Whether continuation of the criminal proceedings, after more than twenty-six years without examination of any prosecution witness, violated the right to speedy trial under Article 21 and amounted to abuse of process warranting quashing of the proceedings.

Analysis: The right to speedy trial is an integral part of the right to life and liberty under Article 21 and applies throughout investigation, inquiry, trial, appeal, revision, and retrial. The governing principle is that each case must be judged on its own facts and circumstances, but prolonged and unexplained delay, especially where the accused is not at fault, may make the proceedings oppressive and unfair. On the facts, the prosecution had remained pending for decades without meaningful progress and without any lapse attributable to the appellant. Continued prosecution in such circumstances would defeat the constitutional guarantee and permit oppressive criminal process to continue indefinitely.

Conclusion: The proceedings were liable to be quashed for violation of the right to speedy trial and for abuse of the process of law, and the appeal was allowed.

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