Fundamental right to speedy trial under Article 21 overriding statutory bail restrictions

The fundamental right to a speedy trial guaranteed under Article 21 of the Constitution of India applies unconditionally across all criminal prosecutions, regardless of the severity or nature of the alleged offense. Statutory restrictions on bail, such as the twin conditions prescribed under Section 45 of the Prevention of Money Laundering Act, 2002 (PMLA), cannot operate to authorize indefinite pretrial detention. When the prosecution machinery or court lacks the capacity to conclude a trial within a reasonable timeframe, statutory limitations must yield to constitutional guarantees. Prolonged incarceration of an undertrial accused without the commencement or reasonable progress of trial violates fundamental personal liberty. Constitutional courts possess inherent authority to grant bail where prolonged pre-trial detention threatens to convert custody into punitive punishment. Consequently, statutory provisions barring bail cannot eclipse constitutional guarantees protecting against indefinite detention without trial. (Arvind Dham v. Directorate of Enforcement | 2026 INSC 12)