The right to a speedy trial is today considered an essential component of justice. Yet, there was a time when thousands of undertrial prisoners in India languished in jails for years without even being formally tried. It was the landmark decision in Hussainara Khatoon v. State of Bihar (1979) that changed this grim reality and expanded the scope of Article 21 of the Constitution.
Background of the Case
In the 1970s, newspapers highlighted shocking reports of undertrial prisoners in Bihar jails that many of them charged with petty offences, languishing for years because their trials had not even begun. A public interest litigation was filed on their behalf. The Supreme Court took cognizance and treated the case as an opportunity to address systemic delays in the criminal justice system.
Judgment of the Supreme Court
The Court, speaking through Justice P.N. Bhagwati, declared that the right to life and liberty under Article 21 includes the right to a speedy trial. It directed the release of undertrial prisoners who had been detained longer than the maximum sentence they would face if convicted.
Significance
The judgment was historic because it turned Article 21 into a tool for reforming criminal justice. It was not limited to individual rights but extended to systemic changes. The Court’s recognition that delay amounts to denial of justice remains a cornerstone in bail hearings and trial delays even today.
Contemporary Relevance
Under BNSS 2023, timelines for investigation and trial have been made stricter, a direct reflection of the principles first laid down in Hussainara Khatoon. The judgment continues to inspire courts to strike down unnecessary delays.
Conclusion
The Hussainara Khatoon case was more than a judgment; it was a humanitarian intervention. By recognizing the right to speedy trial as part of Article 21, the Court ensured that justice delayed would no longer mean justice denied.