The Indian judiciary has been essential in safeguarding the constitutional rights of the people, and it has attempted to give certain rights-such as the right to a fair trial and a swift trial-legal standing by including them all under Article 21 of our Constitution. By giving all Indian people a fair and just trial, the judiciary has actively contributed to the administration of justice in the country. Numerous rulings on the subject of trials have been made by the Supreme Court and High Courts, in which they have questioned the length of the proceedings and found the accused not guilty.

In the area of fundamental human rights, the Supreme Court prior to the emergency has not established any substantial body of precedent. However, the Supreme Court became involved and assertive in this area after the emergency. A new set of fundamental rights has developed, some of which are not stated in the Indian Constitution. For example, the right to a prompt trial has become a stand-alone basic right.

In one of the most exciting moments in the history of judicial activism-the Maneka Gandi v. Union of India case, where Article 21 of the Constitution was properly interpreted-the Supreme Court went on to hold in Hussainara Khatoon that no process that does not guarantee a speedy and reasonable trial can be considered reasonable, fair, or just-and that it would therefore violate Article 21. Therefore, it is without dispute that the fundamental right to life and liberty guaranteed by Article 21 includes a swift trial as a necessary and integral component.

As the protector of citizens' fundamental rights, the State has an obligation to guarantee a prompt trial and prevent needless delays in criminal proceedings that could seriously compromise the integrity of the legal system. A prompt trial is beneficial to society and the general public. Determining the accused's guilt or innocence as soon as feasible is in the best interests of everyone involved. If an accused party can show that their fundamental rights under Article 21 have been violated, the State must then prove that there was no violation of those rights, that the legal restrictions and provisions are reasonable, and that the process followed in this case was just, fair, and expeditious rather than arbitrary.

Judicial Proceedings
In a democratic system, everyone desires freedom. No one can live as a free citizen of a nation without freedom. Only the living are entitled to freedom and liberty. Every individual, whether a citizen or not, is guaranteed the right to life and personal liberty under Article 21 of the Indian Constitution. If two requirements are met-first, there must be a law; and second, there must be a procedure specified by that law-a person may be deprived of his life and personal freedom, provided that the procedure is just, equitable, and reasonable.

When it came to interpreting Article 21, the Indian court system's inventiveness was at its peak, with the possible exception of the brief emergency rule interregnum. For all lovers of freedom, Article 21 shines brightly, offering the expansion of rights as needed and guaranteeing a minimal level of justice in all judicial processes.

The Indian judiciary has been essential in safeguarding the constitutional rights of the people, and it has attempted to give certain rights-such as the right to a fair trial and a swift trial-legal standing by including them all under Article 21 of our Constitution. By giving all Indian people a fair and just trial, the judiciary has actively contributed to the administration of justice in the country. Numerous rulings on the subject of trials have been made by the Supreme Court and High Courts, in which they have questioned the length of the proceedings and found the accused not guilty. The most obvious illness that has plagued the court system is the excessively long processing times and delays in case resolution.

The accumulating backlog of cases and the burden of several courts create a terrifying situation. In actuality, the system as a whole is collapsing under the weight of the daily increase in outstanding cases. All these ailments were known to Justices V.R. Krishna Iyer and P.N. Bhagwati. On the other hand, court delays are common in India. It is impossible for anyone to expect justice in a reasonable amount of time. Criminal court proceedings can last for years or even decades. Even greater delays are seen in civil proceedings.

This is true even if the law greatly favours a prompt trial. The following rulings demonstrate the Court's concern over the issue of trial delays.

A Supreme Court bench consisting of seven judges ruled in State of West Bengal v. Anwar Ali Sarkar that the requirement for a prompt trial "is too vague and uncertain to form the basis of valid and reasonable classification. It is excessively ambiguous because there isn't really a test that can be used to determine it. Since it is not based on any traits that are unique to individuals or situations that must follow the special procedure outlined by the Act, it is not a categorization in the true sense of the word.

Because there was a five-year gap between the time the crime was committed and the Supreme Court's ultimate ruling in Machander v. State of Hyderabad, the court declined to send the case back to the trial court for a new trial. "We are not prepared to keep persons on trial for their lives and under indefinite suspense because trial judges omit to do their duty," the Supreme Court has declared unequivocally.

Striking a good balance between competing rights and obligations is necessary. Even if it is our responsibility to ensure that the guilty do not get away with their crimes, it is even more crucial that those who are suspected of crimes should not face unending harassment. Although individuals tasked with detecting criminal activity and administering justice should be granted every reasonable leeway, there should be restrictions on the extent to which they can go.

One of the reasons the Supreme Court decided not to pursue further proceedings in the Chajoo Ram v. Radhey Shayam case was a trial delay.

In State of Uttar Pradesh v. Kapil Deo Shukla, the court decided that the accused's acquittal was not justified, but it declined to remand the case or set a trial date for 20 years later.

In the case of Maneka Gandhi v. Union of India, the Supreme Court unequivocally ruled that every person has a fundamental right under Article 21 of the Indian Constitution to not have their life or personal liberty taken away from them unless necessary to carry out legal procedures. These legal procedures must be "fair, just, and reasonable," not arbitrary, fanciful, or oppressive.

The court went on to say that "a person would be entitled to enforce such fundamental right and secure his release if he is deprived of his Liberty under a procedure which is not reasonable, fair, or just.'" This means that the deprivation would violate the individual's fundamental right under Article 21. The Supreme Court has noted that the right to a quick trial is contained in the general provisions of Article 21.

The ruling in Hussainara Khatoon v. Home Secretary, State of Bihar by the Supreme Court marks a turning point in the development of the law pertaining to expedited trials. A writ of habeas corpus was filed in the present case on behalf of men and women who are being held in jails in the State of Bihar while they await trial. Some of them had spent far longer time behind bars than they would have if the maximum penalty for the offence they were charged with had been applied to them.

The Supreme Court went on to give a new orientation to constitutional jurisprudence, alarmed by the startling findings revealed in the writ petition and concerned about the denial of basic human rights to those "victims of callousness of the legal and judicial system." The Court did this by largely drawing on its ruling in a previous case where it interpreted Article 21 of the Constitution in a fairly progressive manner.

P.N. Bhagwati J., following this view to its logical conclusion, stated in Hussainara Khatoon's case:
"...a legal mechanism for removing someone from their liberty cannot be rational, fair, or just unless it guarantees a prompt trial to ascertain the person's guilt. No process can be deemed "reasonable, fair, or just" if it does not guarantee a fairly swift trial; this would violate Article 21. Therefore, it is beyond dispute that the fundamental right to life and liberty guaranteed by Article 21 includes the necessity of a swift trial-by which we mean a trial that proceeds reasonably quickly.

Bhagwati, J. further stated that the State cannot be allowed to refuse the right to a speedy trial under the Constitution on the grounds that it lacks the financial means to pay for the upgrades to the judicial and administrative systems that would guarantee a speedy trial. Regarding the implications of violating the right to a quick trial, the Court was asked about it but declined to provide a response.

The ruling in this case turned out to be the cornerstone of India's right to a prompt trial. As the guardian of the people's fundamental rights and as sentinel on the qui vive, the Court categorically declared that "it is also the constitutional obligation of this Court to enforce the fundamental right of the accused to speedy trial by issuing necessary directions to the state which may include taking of positive action, such as augmenting and strengthening the investigative machinery, setting up new courts, building new court houses, providing more staff and equipment to the Courts.

The law established in Hussainara Khatoon's case was upheld by the Supreme Court in several other rulings. In the case of State of Bihar v. Uma Shankar Ketriwal, the High Court dismissed the proceedings, citing the prosecution's 16-year-old start and ongoing case as an abuse of the legal system that should not be let to continue.

The Supreme Court declined to overturn the High Court's decision in the appeal, stating that there must be a time limit on how long criminal litigation can continue at the trial stage because such a protracted process in and of itself causes significant harassment for the accused. Additionally, the Court noted, we cannot lose sight of the fact that the trial has not made much progress even though at least 20 years have passed. Such protection itself means considerable harassment to the accused, apart from anxiety, in terms of constant attention to the case and repeated appearances in Court.

There must be a cap on the amount of time that criminal litigation can continue during the trial stage, so it is possible to argue that the respondents bear some of the blame for the case's slow progress. Several of the trial magistrate's orders were contested in higher courts.

The aforementioned claims have been repeatedly emphasised by the Supreme Court. The Supreme Court noted in Kartar Singh v. State of Punjab that "the fundamental right to life and liberty guaranteed and preserved in our Constitution is a part that is essential to the concept of speedy trial, which is read into Article 21." In order to allege any potential prejudice resulting from an unlawful and avoidable delay from the time of the offence until it culminates in a finality, this right to a speedy trial starts with the actual restraint imposed by the arrest and subsequent incarceration and continues through all stages of investigation, inquiry, trial, appeal, and revision.

The Supreme Court noted in Anil Rai v. State of Bihar that justice ought to be served and ought to look as though it has been served. In the same way that delayed justice is the same as denied justice, withheld justice is far worse.

The Supreme Court ruled in N.S. Sahni v. Union of India that an accused person's right to a prompt trial is now recognised as a right under Article 21. Thus, it is imperative that the procedural justice mandated by Article 21, which includes the right to a prompt trial, be upheld at all times and kept front and centre.

In a recent instance, the Supreme Court expressed concern that skilled criminals would take advantage of setting a deadline for finishing a criminal prosecution. During the hearing on a petition filed by advocate Ranjan Dwivedi, who sought the quashing of the trial proceedings against him in the L.N. Mishra murder case on the grounds of an excessive delay of 37 years, a Division Bench made up of Justices H.L. Dattu and C. K. Prasad found that the trial had negatively impacted him on a personal, physical, and social level. According to the Supreme Court, the right to a prompt trial is a prerequisite under Article 21, which protects the right to life. However, the trial has continued for 37 years.

The Supreme Court ordered a day-to-day trial in 1992 in order to expedite the case's resolution. We are far from the end even after twenty years. The bench stated that the Indian legal system had a history of frequent delays. With the current system in place, delays will persist. Although a delay undoubtedly affects the trial, the Supreme Court has the authority to set a deadline for finishing a criminal trial. The Supreme Court had already expressly invalidated the setting of a deadline for the conclusion of the trial in a ruling, the statement stated.

The Court said, "This is a unique circumstance. But if we put an end to the proceedings, we might be sending the wrong message, which could subsequently be used by a cunning accuser. We do not want this to happen as a result of our order. The bench said it might ask the trial court to conclude the trial within the next three months by holding daily sessions and not allowing the accused or the prosecution any form of delay because the trial had finally come to an end after nearly forty years.

Conclusion
In summarising all the court rulings concerning the right to a fast trial, it is important to acknowledge that Indians are not receiving prompt justice. Overly protracted proceedings are becoming a standard part of the Indian legal system. Although the State has developed several steps and the judiciary has rendered several judgements aimed at eliminating delay, the goal of a rapid trial has not yet materialised.

A new, comprehensive law pertaining to the expeditious trial of cases is required. The goal of expediting the trial of offenders should be achieved by appropriately amending the criminal legislation. A campaign of awareness for a prompt trial of offenders ought to be launched.

It is shown that while the right to a speedy trial is not expressly mentioned in the Indian Constitution, it has been interpreted as a basic right through the interpretation of Article 21. The right to a prompt trial is protected under the Code of Criminal Procedure in addition to the Indian Constitution. The judiciary has played a pivotal role in elevating this right to the realm of fundamental rights.

It is impossible for anyone to expect justice in a reasonable amount of time. Criminal court proceedings can last for years or even decades. This is true even if the law greatly favours a prompt trial.