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Issues: Whether prolonged custody pending trial or appeal, in the face of the constitutional guarantee of speedy trial, warranted bail or other time-bound relief, and what systemic directions were necessary to secure expeditious criminal justice administration.
Analysis: Speedy trial is an integral part of Article 21 and prolonged deprivation of liberty pending trial or appeal cannot be permitted to become unduly long. Section 436A of the Code of Criminal Procedure, 1973 reflects the legislative concern against excessive undertrial detention, while prior decisions have recognized that where criminal proceedings are not concluded within a reasonable time, courts may either grant bail or direct expeditious disposal. The Court also noted persistent systemic delay in criminal trials and appeals, the need for active monitoring by High Courts, and the importance of action plans, infrastructure, reduced adjournments, and priority for long-pending custody cases.
Conclusion: The specific appeals were disposed of by directing expeditious completion of the pending trial and appeal within a fixed time, and the High Courts were requested to issue and monitor broad administrative and judicial directions to secure speedy disposal of custody cases, bail matters, and long-pending criminal proceedings.
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