Speedy trial under Article 21 is assessed case by case; prolonged delay alone does not automatically justify quashing proceedings.

The right to speedy trial under Article 21 is a facet of constitutional fairness and must be assessed on the totality of circumstances, including the length and reasons for delay, prejudice, and the conduct of the parties. No universal outer time-limit can be fixed for quashing criminal proceedings solely because trial has remained pending for a long period, and quashing is not automatic in every delayed prosecution. On the facts stated, the post-1991 delay was mainly attributable to the accused, and the record did not show oppressive prosecution or prejudice sufficient to justify quashing. The challenge based on denial of speedy trial therefore failed.

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Issues: Whether the criminal proceedings were liable to be quashed on the ground that the prolonged pendency of the trial amounted to denial of the fundamental right to speedy trial under Article 21 of the Constitution of India.

Analysis: The right to speedy trial is a facet of Article 21 and must be assessed on a balancing of all relevant circumstances, including the length of delay, the reasons for delay, prejudice, and the conduct of the parties. The settled law does not permit prescribing any universal outer time-limit for termination of criminal proceedings, and quashing is not automatic merely because the trial has remained pending for a long period. On the facts found, the delay after 1991 was attributable principally to the accused, and the record did not justify holding that the prosecution had become oppressive or that the trial had suffered a violation warranting quashing.

Conclusion: The challenge based on denial of speedy trial failed, and the proceedings were not liable to be quashed.

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