ISSUE:
Whether the failure to provide free legal aid to an indigent accused vitiates the trial?
Whether it is the duty of the court to inform an accused of their right to free legal aid, even if no request is made?
RULE:
A fair trial mandates legal representation for an accused who cannot afford a lawyer, as it is an essential component of the right to life and personal liberty under Article 21. The requirement of a "fair, just, and reasonable procedure" encompasses the duty of the State to provide a lawyer where the accused lacks means. This principle is absolute in cases where imprisonment is a possible outcome.
Legal aid cannot be conditioned upon an accused making a request. A majority of the population is illiterate and unaware of their legal rights, making it unreasonable to expect them to demand free legal aid. Without explicit information from the court, the right becomes meaningless.
A trial conducted without informing an indigent accused of their right to legal aid is inherently unfair and unconstitutional. The adversarial system places an unrepresented accused at a significant disadvantage. The failure to ensure legal representation compromises the defense, leading to an unfair trial.