Exceptional delay tactics can justify a time-bound direction for disposal and strict control of adjournments in criminal complaint proceedings.

A constitutional court may direct time-bound disposal of a pending complaint only in exceptional circumstances, where the record shows persistent delay tactics and repeated abuse of adjournments. In the described matter, successive applications and adjournment requests were used to postpone final arguments after defence evidence had closed, justifying a strict trial-management direction. The court therefore required the complaint under Section 138 of the Negotiable Instruments Act to be decided within one month, disallowed further adjournments for final arguments, and required pending applications to be taken up the same day.

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Issues: Whether exceptional circumstances were made out to direct the trial court to decide the complaint under Section 138 of the Negotiable Instruments Act, 1881 within a fixed time and to regulate adjournments for final arguments.

Analysis: The application was under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023. The record showed repeated attempts by the accused to delay final hearing through successive applications and adjournment requests, despite closure of the right to lead defence evidence and repeated fixing of the matter for final arguments. In the circumstances, the matter was treated as one falling within the exceptional category where a time-bound direction could be issued, consistent with the principle that such directions should ordinarily be reserved for extraordinary situations.

Conclusion: The request for an expeditious decision was accepted. The trial court was directed to decide the complaint within one month and to grant no adjournment to the respondent for final arguments, with all pending applications to be decided on the same day.

Final Conclusion: The application was allowed to the extent of issuing binding directions for prompt disposal of the complaint and for preventing further delay at the trial stage.

Ratio Decidendi: A constitutional court may issue a time-bound direction for disposal of a pending case only in exceptional circumstances, particularly where the record discloses persistent abuse of adjournments and delay tactics that frustrate final adjudication.

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