Meaningful legal aid in capital trials requires real preparation time; same-day appointment and rushed proceedings can vitiate conviction.

Free legal aid is part of the Article 21 guarantee of a fair, reasonable and just procedure, and a mere same-day appointment of counsel does not satisfy that standard. Meaningful assistance requires time to study the record, consult the accused and prepare the defence. On the facts noted, counsel was appointed on the day charges were framed, the trial moved forward at exceptional speed, and expert evidence was concluded hastily. Because the case involved the possibility of death sentence, the procedure was treated as a serious infirmity that denied a real opportunity of defence. The conviction and sentence were set aside and the matter was remitted for fresh consideration in accordance with law.

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Issues: Whether the appointment of legal aid counsel on the same day as framing of charges, followed by a highly compressed trial, denied the accused real and meaningful legal assistance and vitiated the conviction and sentence, warranting a de novo consideration.

Analysis: The Court reiterated that free legal aid is an essential ingredient of a fair, reasonable and just procedure and that the right under Article 21 is not satisfied by a mere formal appointment of counsel. Meaningful assistance requires sufficient time to study the record, consult the accused and prepare the defence. The record showed that the amicus curiae was appointed on the day charges were framed, that the trial progressed immediately thereafter, and that the evidence, including expert material, was concluded with exceptional haste. In a case where death sentence was one of the possible punishments, such procedure deprived the accused of a real opportunity to defend himself and resulted in a serious infirmity in the trial.

Conclusion: The conviction and sentence were set aside and the matter was directed to be considered afresh in accordance with law.

Final Conclusion: The appeals succeeded to the extent that the earlier findings of guilt and sentence could not stand, and the case was remitted for de novo consideration while leaving the merits open.

Ratio Decidendi: In a criminal trial, especially where capital punishment is possible, legal aid must be real and meaningful, and failure to afford counsel sufficient time and opportunity to prepare the defence violates fair trial requirements and vitiates the resulting conviction and sentence.

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