Robert Lalchungnunga Chongthu @ R L Chongthu vs. State of Bihar
Background
The case arose from an FIR registered in 2005 alleging offences connected with fabricated arms licenses, in which the appellant (accused of authorising licenses, including to a fictitious person) faced an investigation that dragged on for over two decades, with more than a decade spent investigating just his role after other co-accused had already been chargesheeted. The Patna High Court had refused to quash the proceedings against him. He approached the Supreme Court arguing that this extraordinary and unexplained delay violated his right to a speedy investigation and trial.
Decision Breakdown
The Supreme Court surveyed Indian and comparative (Canadian, South African) law on delayed investigations and held that although no strict statutory timelines exist for completing an investigation in India, an investigation cannot continue endlessly without justification. Finding no reasonable explanation for the roughly 11-year delay concerning the appellant specifically, the Court held this violated his right to a speedy investigation/trial under Article 21 and quashed the prosecution against him. The Court also issued broader directions: courts retain supervisory control over further investigations conducted with their leave, reasons must be furnished for large gaps between FIR and chargesheet, and an accused or complainant facing unduly long investigation delay may approach the High Court under Section 528 BNSS/Section 482 CrPC for an update or quashing.
Lesson Learnt
The right to a speedy trial under Article 21 extends to the investigation stage itself. If an investigation drags on for years without justification, the affected person can approach the High Court to seek an update or even quashing of the proceedings, rather than being made to live indefinitely under the cloud of an unresolved criminal case.