Inordinate criminal trial delay can justify quashing proceedings where continued prosecution would amount to undue harassment and abuse of process.

Excessive and unexplained delay in a criminal trial may by itself justify non-interference with an order quashing the proceedings, because prolonged pendency can amount to undue harassment and abuse of process. Although the allegations were treated as serious and the police report was said to be open to criticism for not disclosing an offence, the case had remained pending for about two decades with little progress. The SC held that such inordinate trial delay furnished sufficient ground to decline revival of the prosecution, and the challenge to the quashing failed.

---

---

Issues: Whether the quashing of the criminal proceedings was justified on the grounds of absence of offence in the police report and the inordinate delay in the trial.

Analysis: The allegations were treated as disclosing a serious offence, and the Court indicated that the finding that the police report did not disclose any offence was open to criticism. However, the proceedings had remained pending for about two decades, with the trial making little progress. The Court held that such prolonged pendency causes substantial harassment to the accused and that criminal litigation cannot be permitted to continue indefinitely at the trial stage. On that basis, the delay itself furnished sufficient reason to decline interference with the order quashing the proceedings.

Conclusion: The quashing of the proceedings was upheld, and the challenge to it failed.

Final Conclusion: Inordinate and unexplained protraction of a criminal trial may justify refusal to revive the proceedings, even where the allegations are serious.

Ratio Decidendi: Excessive delay in the trial of a criminal case may itself justify quashing or non-interference where continuation of the prosecution would amount to undue harassment and abuse of the process of court.

---