The correct option is Right to fair and speedy trial.
Explanation
Article 21 of the Constitution of India guarantees the Right to Life and Personal Liberty. The Supreme Court has interpreted this article expansively to include various implied rights, establishing that the procedure established by law must be "fair, just, and reasonable." Consequently, the right to a speedy trial is recognized as an integral part of the fundamental right to life and liberty.
Case Analysis
The case of Machal Lalung is a significant instance in Indian legal history regarding the rights of undertrial prisoners.
- Background: Machal Lalung, a resident of Assam, was arrested in 1951. He was subsequently transferred to a mental hospital in Tezpur.
- Violation: Despite being fit for release or trial at various points, administrative negligence resulted in him remaining in custody as an undertrial prisoner for 54 years without ever facing a trial.
- Outcome: He was released in 2005 following the intervention of the National Human Rights Commission (NHRC). His prolonged incarceration without trial highlighted a systemic failure in the justice delivery system, specifically violating the constitutional guarantee of a fair and speedy trial under Article 21.
Key Takeaway: The right to a speedy trial is a fundamental right implicit in Article 21; indefinite incarceration of an undertrial prisoner constitutes a violation of their personal liberty.