Speedy trial delay did not justify quashing where forgery and cheating allegations were serious and the trial had already progressed.

The Delhi High Court declined to quash the FIR and chargesheet on the ground of delay, holding that Article 21 speedy-trial concerns do not justify interference where the allegations are serious and the trial has substantially progressed. The Court noted charges had been framed and prosecution evidence had begun, and found that the delay relied on was not of the kind that made the proceedings constitutionally unfair. The criminal case was therefore allowed to continue, with a direction for expeditious completion of the trial.

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Issues: Whether the FIR and chargesheet should be quashed on the ground of inordinate delay in trial and alleged absence of offences.

Analysis: The petition invoked the constitutional guarantee of a speedy trial under Article 21 and relied on delay as the principal ground for quashing. The Court noted the long pendency of the case, but also observed that the allegations were serious, involving forgery, cheating, use of forged documents, and conspiracy. The record showed that the charges had been framed and prosecution evidence had begun, and the delay pleaded was not of the kind found in the cited precedents so as to justify quashing the proceedings.

Conclusion: The petition for quashing was not allowed; the FIR and chargesheet were sustained.

Final Conclusion: The criminal proceedings were permitted to continue, with a direction for expeditious completion of the trial.

Ratio Decidendi: Quashing on the ground of delay is not warranted where the allegations are serious and the trial has substantially progressed, unless the delay is shown to make the proceedings unfair in the constitutional sense.

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