Prolonged Incarceration Without Trial Grounds for Bail, Rules Supreme Court

The Supreme Court of India in SAHIL MANOJ MACHARE VS THE STATE OF MAHARASHTRA has reiterated that the constitutional right to a speedy trial cannot be compromised, even in serious criminal cases, while granting bail to an undertrial accused charged with murder. A Bench of Justice J. B. Pardiwala and Justice Vijay Bishnoi allowed the plea, emphasizing that prolonged incarceration without trial violates Article 21 of the Constitution.

The accused had been in judicial custody since November 1, 2022, in connection with offences under Sections 302 and 34 of the Indian Penal Code, 1860. Despite charges being framed in 2024, not a single witness had been examined, reflecting significant delay in trial proceedings. The bail plea had earlier been rejected by the Bombay High Court (Kolhapur Bench), prompting the accused to approach the apex court.

Setting aside the High Court’s order, the Supreme Court observed that “howsoever serious the crime may be,” courts must consider bail where the right to speedy trial is infringed. It noted that continued detention in such circumstances would be unjustified, especially when there are no reasonable prospects of the trial concluding in the near future.

The Court held that the accused’s fundamental right under Article 21 of the Constitution of India had been violated due to the inordinate delay. Accordingly, it directed that the petitioner be released on bail, subject to conditions imposed by the trial court.

This ruling reinforces the judiciary’s consistent stance that procedural delays cannot override personal liberty, even in grave offences.