ISSUE:
Whether the petitioners’ fundamental right to a speedy trial under Article 21 of the Constitution has been violated due to the prolonged delay of 37 years in the trial?
Whether the delay in the trial is attributable to the prosecution, systemic inefficiencies, or the accused themselves?
Whether the prolonged delay justifies quashing the criminal proceedings against the accused?
RULE:
Right to a speedy trial is implicit in Article 21 and extends to all stages of the criminal process, including investigation, trial, appeal, and revision. The delay must be assessed in the context of all attendant circumstances rather than through a fixed timeframe.
Delay alone is not conclusive; it must be weighed against the nature of the offense, the complexity of the case, the conduct of the parties, and the justification for the delay.
Systemic delays do not automatically violate the right to a speedy trial, unless they cause oppression, undue prejudice, or render a fair trial impossible.
An accused cannot claim the benefit of delay if they contributed to it, whether through adjournments, procedural tactics, or legal maneuvers.