Introduction 

• In this case speedy trial was held as the fundamental right of the prisoners under Article 21 of the Constitution of India, 1950 (COI). 

Facts 

• In this case a writ of Habeas Corpus was filed before the Supreme Court in which it was inferred that the prisoners are denied of their right to speedy trial guaranteed under COI. 
• It was also stated that prisoners are denied of bail and are detained even after expiration of their detention period in the jails of Patna & Muzaffarpur. 
• The plaintiff, who had been in jail for 4-5 years, remained detained despite a direct government order to release prisoners held under the Foreigners Act (1946).    

Issues Involved  

• Whether Article 21 of the COI covers the right to speedy trial? 
• Whether the right to free legal aid should be a part of Directive Principles of State Policy? 

Observations 

• The Supreme Court in this case held that Right to speedy trial is covered under Article 21 of the COI and there should be no discrimination in exercising of the rights under COI. 
• The court also ordered the state government and High court to make a list of the prisoners who are being detained for more than the detain period and have been denied bail. 
• It was also ordered by the Supreme Court that the right to free legal aid is a part of Directive Principles of State Policy.  

Conclusion 

• The Supreme Court held that Article 21 guarantees Right to live in a dignified way and not merely animal existence.  
• The Supreme Court ordered free legal aid to under-trial prisoners charged with bailable offences.   
• Finally, the Supreme Court ordered the release of all the under-trial prisoners whose names were present in the list with bonds.