Speedy trial rights protect accused persons from oppressive, unexplained delays in minor criminal prosecutions under Article 21.

The right to a speedy trial forms part of fair, just and reasonable procedure under Article 21 and applies throughout criminal proceedings. Whether delay violates that right requires an overall assessment of the offence's nature and complexity, responsibility for delay, prejudice to the accused, and the balance between individual liberty and societal interests; no fixed outer limit applies. The notes state that a prolonged, unexplained prosecution for minor offences, coupled with lack of prosecution evidence and resulting prejudice to a public servant, was oppressive and unfair. The criminal trial was directed not to continue.

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Issues: Whether continuation of a criminal prosecution for 35 years for minor offences violated the appellant's right to a speedy trial under Article 21 of the Constitution of India.

Analysis: The right to a speedy trial is an integral component of fair, just and reasonable procedure under Article 21 and extends through every stage of criminal proceedings. Whether delay infringes that right depends on the overall circumstances, including the nature and complexity of the offence, responsibility for delay, prejudice to the accused, and the balancing of individual liberty with societal interests; no universal outer time-limit can be prescribed. Here, the prosecution concerned a trivial altercation involving simple hurt and criminal intimidation, remained pending for 35 years without any attributable cause or explanation, and the co-accused had already been acquitted because the prosecution led no evidence. The prolonged pendency kept the appellant, a public servant, in suspended animation and was oppressive and unfair.

Conclusion: The appellant's right to a speedy trial under Article 21 was violated; the criminal trial and prosecution against him shall proceed no further.

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