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Abdul Rehman Antulay & Ors vs R.S. Nayak & Anr on 10 December, 1991

17. The legal expectation of expedition and diligence being present at every stage of a criminal trial and a fortiori in departmental enquiries has been emphasised by this Court on numerous occasions. The Constitution Bench in Abdul Rehman Antulay v. R.S. Nayak [(1992) 1 SCC 225 : 1992 SCC (Cri) 93] underscored that this right to speedy trial is implicit in Article 21 of the Constitution and is also reflected in Section 309 of the Code of Criminal Procedure, 1973; that it encompasses all stages viz. investigation, inquiry, trial, appeal, revision and retrial; that the burden lies on the prosecution to justify and explain the delay; that the Court must engage in a balancing test to determine whether this right had been denied in the particular case before it. Keeping these factors in mind CAT had in the case in hand directed that the appellant's suspension would not be extended beyond 90 days from 19-3-2013. The High Court had set aside this direction, viewing it as a substitution of a judicial Page 8 of 11 determination to the authority possessing that power i.e. the Government."
Supreme Court of India Cites 58 - Cited by 715 - B P Reddy - Full Document

Sandipta Gangopadhyay vs Allahabad Bank & Ors on 21 April, 2015

The authority by its conduct, should justify the purpose of the suspension of the person. Even in case of a deemed suspension under the Rules, as in case of the present writ petitioner, he cannot be left in vacuum, to suffer a stigma for an uncertain vast future period. Thus by dint of the verdict of the Courts, the period of suspension has been acknowledged to be limited and not to continue indefinitely, till the criminal trial is concluded. As it is held in Sanditpa Gangopadhyay's case (supra), that the trial in a Court may face various impediments and its period could be elongated for multifarious reasons attributable to various stakeholders. Continuing to restrain a person to join in duty and paying him allowance, would not be justifiable, in such an eventuality.
Calcutta High Court (Appellete Side) Cites 3 - Cited by 3 - S Banerjee - Full Document
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