Speedy trial under Article 21 does not automatically undo conviction absent prejudice; complete circumstantial chain sustained guilt.

Delay in trial does not automatically vitiate a prosecution under Article 21; relief depends on whether the accused contributed to the delay and whether actual prejudice to the defence was shown. Applying that principle, the accused was found responsible for part of the delay and failed to establish prejudice, so no acquittal was warranted on the speedy-trial ground. In the circumstantial-evidence issue, the proved facts, including presence at the scene, recovery of gold slabs with foreign markings, and possession of keys fitting the almirah and flat door, formed a complete chain inconsistent with innocence. The acquittal was set aside and the conviction and sentence restored.

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Issues: (i) Whether delay in trial, by itself or in the facts of the case, vitiated the prosecution and entitled the accused to acquittal on the ground of violation of the right to speedy trial under Article 21 of the Constitution of India; (ii) Whether the circumstances proved against the accused were sufficient to justify reversal of the High Court's acquittal and restoration of the conviction.

Issue (i): Whether delay in trial, by itself or in the facts of the case, vitiated the prosecution and entitled the accused to acquittal on the ground of violation of the right to speedy trial under Article 21 of the Constitution of India.

Analysis: The right to speedy trial is treated as an integral part of the right to life and personal liberty because a procedure that does not ensure a reasonably expeditious trial cannot be regarded as reasonable, fair or just. At the same time, delay does not automatically nullify a conviction in every case. The Court considered whether the accused contributed to the delay and whether any prejudice to the defence was shown. On the facts, the accused was responsible for a fair part of the delay and failed to establish prejudice in the conduct of the defence.

Conclusion: The delay did not entitle the accused to acquittal and no violation warranting interference was made out on this ground.

Issue (ii): Whether the circumstances proved against the accused were sufficient to justify reversal of the High Court's acquittal and restoration of the conviction.

Analysis: The proved circumstances included the accused's presence in the flat at the time of the raid, recovery of gold slabs with foreign markings from the almirah, recovery from the accused of keys fitting the almirah, and recovery of a key fitting the lock on the flat door. The Court held that these circumstances formed a coherent chain inconsistent with innocence. The explanation accepted by the High Court was found to be wholly unreasonable, and the reluctance to interfere with an acquittal was outweighed by the need to prevent miscarriage of justice.

Conclusion: The circumstances were sufficient to establish guilt and the acquittal was liable to be set aside.

Final Conclusion: The appeal succeeded, the acquittal was reversed, and the conviction and sentence recorded by the trial court were restored.

Ratio Decidendi: Speedy trial is implicit in Article 21, but delay warrants relief only where the accused shows prejudice or other circumstances justifying the inference that the trial was unfair; in a circumstantial case, a conviction may be sustained where the proved facts form a complete chain inconsistent with innocence.

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