Right to Speedy Trial is an Integral and Essential Part of Fundamental Right to Life

In a pivotal judgment the Supreme Court of India, comprising Justices C.T. Ravikumar and Sudhanshu Dhulia, underscored the importance of the right to a speedy trial, affirming that it is “an integral and essential part of the fundamental right to life and liberty.” This landmark ruling came in the case of “2023 INSC 1028” where the appellant, Amandeep Singh Saran, challenged the jurisdictional competence of the Court of Chief Judicial Magistrate, Raipur, to try his case involving various offences under the IPC and other Acts.

The Court delved into a comprehensive analysis of the Code of Criminal Procedure, 1973 (Cr.PC), and the Indian Penal Code, 1860 (IPC), to address the legal conundrum surrounding the appropriate judicial forum for trials involving offences punishable with life imprisonment or imprisonment of up to 10 years. The judgment critically highlighted the limitations of the punitive jurisdiction of the Court of Chief Judicial Magistrate, Raipur, in cases involving severe penalties.

In their observation, the justices referred to the necessity of a speedy trial as a facet of a fair trial, invoking past precedents such as Maneka Gandhi v. Union of India and Abdul Rehman Antulay v. R.S. Nayak. The Court emphasized the significance of conducting trials before a competent court, stating, “The accused should not be subjected to unnecessary or unduly long incarceration prior to his conviction.”

The judgment also paved the way for a new directive, ordering the committal of the appellant’s case to the Court of Session under Section 323 of the Cr.PC. This move ensures that the trial is conducted by a court possessing the jurisdictional competence to try offences under Section 409 IPC, thereby safeguarding the rights of the accused to a fair trial.

Date of Decision: November 29, 2023

Amandeep Singh Saran  VS State of Chhattisgarh