Speedy trial right under Article 21 can justify quashing prolonged criminal prosecutions when delay becomes oppressive.

Prolonged criminal prosecutions with repeated adjournments and little progress were treated as an infringement of the constitutional right to a speedy trial under Article 21. The Court's reasoning emphasised that delay can become oppressive and defeat fair process where there is no realistic prospect of early conclusion, especially when the matters are numerous, witnesses are many, and the cases have remained stalled across transfers between courts. On that basis, the inordinate delay was found to justify quashing of the proceedings.

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Issues: Whether the prolonged pendency of the criminal prosecutions, with little progress over many years and no realistic prospect of early conclusion, justified quashing of the proceedings on the ground of denial of the right to a speedy trial under Article 21 of the Constitution of India.

Analysis: The prosecutions had remained pending for an exceptionally long period, with repeated adjournments and no effective progress. The Court treated the constitutional guarantee of speedy trial as an integral part of Article 21 and held that criminal proceedings cannot be permitted to continue indefinitely where the delay itself becomes oppressive and destructive of the accused's rights. The Court also noted that, given the number of cases, the number of witnesses, the transfer of matters between courts, and the stage at which the cases stood, there was no reasonable likelihood of disposal within a short time.

Conclusion: The inordinate delay amounted to a denial of the petitioner's right under Article 21, and the prosecutions were quashed.

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