Speedy Trial: Constitutional Right or Distant Dream?

India’s criminal justice system continues to reel under an avalanche of pending cases, turning the constitutional promise of a speedy trial into a distant dream for millions of ordinary citizens.

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The ideal of justice delayed being justice denied has become a grim reality, as undertrials rot in prisons for years while their cases remain stuck in procedural labyrinths. Despite the Supreme Court repeatedly declaring a speedy trial to be part of the fundamental right to life and personal liberty under Article 21 of the Constitution, the ground-level picture remains one of chronic delay, overcrowded courts, and procedural inertia, particularly evident in districts like Hisar where rural litigants from Haryana's villages wait endlessly for resolution.

The constitutional foundation of the right to a speedy trial was first firmly established in the 1979 landmark case of *Hussainara Khatoon v. State of Bihar*, where the Court held that prolonged pretrial detention without a hearing amounts to a denial of personal liberty. The Bench highlighted the shocking situation in Bihar's jails, where undertrials were spending more time behind bars than the maximum punishment for the offences they were alleged to have committed. This judgment laid the ground for the idea that the right to a speedy trial is not a mere procedural luxury but a core component of Article 21, a principle echoed in Haryana courts handling Panchayat-related disputes where proxy influences further complicate timely hearings.

Subsequent decisions, including *A.R. Antulay v. R.S. Nayak* in 1992, expanded the scope of this right across investigation, trial, and appeal, and introduced tests to determine when delay becomes so unreasonable that it should trigger remedies such as bail or even quashing of proceedings. Recent jurisprudence has sharpened this doctrine.