In a landmark judgment, the Supreme Court of India has reinforced the fundamental right to a speedy trial, emphasizing that prolonged incarceration of undertrial prisoners without timely adjudication constitutes a violation of Article 21 of the Constitution. The ruling came in the context of a bail application filed by an individual accused under the Unlawful Activities (Prevention) Act (UAPA), who had been in custody for over five years without a conclusive trial.
Case Background
The petitioner was arrested by the Chhattisgarh Police in 2020 on allegations of possessing materials purportedly linked to Naxalite activities. Charged under the stringent provisions of the UAPA, the accused remained in judicial custody as the trial progressed at a sluggish pace. The prosecution listed 100 witnesses to substantiate its case, of which only 42 had been examined over the five-year period.
Judicial Observations
A bench comprising Justices JB Pardiwala and R Mahadevan critically assessed the necessity of examining an extensive list of witnesses, especially when the testimonies of the 42 examined thus far appeared repetitive and corroborative of the same facts. The Court questioned the prosecutorial strategy, suggesting that the examination of 100 witnesses to establish a singular fact was superfluous and contributed to undue delays in the trial process.
Citing the precedent set in Malak Khan vs. Emperor [AIR 1946 Privy Council 16], the Court reiterated that when a large number of witnesses are available, it is not imperative to produce each one, particularly if their testimonies are redundant. This principle aims to streamline judicial proceedings and prevent unnecessary prolongation of trials.
Right to Speedy Trial Under Article 21
The Supreme Court underscored that the right to a speedy trial is an intrinsic component of the right to life and personal liberty guaranteed under Article 21 of the Indian Constitution. The Court observed that subjecting an individual to an extended period of incarceration as an undertrial prisoner, especially spanning six to seven years, without delivering a final verdict, unequivocally infringes upon this fundamental right.
The ramifications of protracted trials are multifaceted, adversely affecting the accused, victims, and the justice system at large. For the accused, prolonged detention leads to psychological stress, social ostracism, financial instability, and the erosion of personal relationships. Even in instances where the accused is eventually acquitted, the absence of compensatory mechanisms means they are left to rebuild their lives independently, bearing the scars of societal stigma and personal loss.
Impact on the Justice System
The Court highlighted that judicial delays erode public confidence in the legal system, as justice delayed is tantamount to justice denied. For victims, extended trials prolong the trauma and defer the closure they seek. From an institutional perspective, backlog of cases and delayed proceedings strain judicial resources and undermine the efficacy of the justice delivery mechanism.
Directive for Expedited Trials
In light of these considerations, the Supreme Court granted bail to the petitioner, emphasizing the necessity for courts to exercise judicious discretion in admitting evidence and determining the relevance and number of witnesses. The ruling serves as a clarion call for the judiciary to adopt measures that prevent inordinate delays, ensuring that the right to a speedy trial is upheld in both letter and spirit.
Conclusion
This judgment reaffirms the Supreme Court's commitment to safeguarding fundamental rights and underscores the imperative for systemic reforms to address delays in the criminal justice process. By holding that extended undertrial detentions without timely verdicts violate constitutional rights, the Court has set a precedent aimed at fostering a more efficient and equitable legal system.
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