Rahul Alias Billu vs. The State of NCT of Delhi
Background
The applicant, who had been in judicial custody for more than two and a half years in a case investigated by the Special Cell, sought to withdraw his bail application, reserving the right to file it afresh if the trial was not concluded within a reasonable time. The Court noted that the prosecution had already examined about 20 of the 32 witnesses in the case.
Decision Breakdown
The Investigating Officer, present in Court, undertook to fully cooperate in early completion of the trial and agreed not to seek adjournments on any pretext. Taking into account the applicant's prolonged incarceration and the fact that the case was substantially through its evidence stage, the Court directed the trial court to conclude the trial within six months from receipt of its order, and disposed of the bail application on that basis, granting the applicant liberty to file a fresh bail application if the trial was not concluded within that period.
Lesson Learnt
When an undertrial has spent a long time in custody, courts can use their supervisory powers to direct time-bound completion of the trial itself, rather than simply granting or denying bail, giving the accused a concrete fallback (a fresh bail plea) if that timeline is not honoured.