Vickki Yadav @ Vikas Yadav v. State of Uttar Pradesh, 2026

The petitioner was accused in a criminal case involving offences under Sections 147, 148, 149, 120B, and 302 IPC, including the offence of murder.

The petitioner sought bail before the Allahabad High Court, but his application was rejected.

The petitioner challenged the High Court's order before the Supreme Court.

During the hearing, it was brought to the Court's notice that the petitioner had remained in custody as an undertrial prisoner for more than nine years.

It was also submitted that the criminal trial was at its fag end but had not yet concluded.

The petitioner relied upon the fact that a co-accused had already been granted bail by the Supreme Court on 29 April 2026.

The High Court had rejected bail relying upon the Supreme Court's decision in X v. State of Rajasthan (2024).

According to the High Court, once trial had commenced in serious offences, bail should ordinarily not be granted and the proceedings should be allowed to conclude.

The petitioner argued that the High Court had misunderstood the ratio of the 2024 judgment and had failed to consider his fundamental right to a speedy trial.

The Supreme Court examined whether continued incarceration for more than nine years as an undertrial amounted to a violation of Article 21.

The Supreme Court allowed the petition and granted bail to the petitioner.

The Court held that the Allahabad High Court had misunderstood the true purport of the judgment in X v. State of Rajasthan (2024).

The Court clarified that the 2024 judgment does not lay down an absolute rule that bail cannot be granted once the trial has commenced.

The Court observed that where there is undue delay in trial for no fault attributable to the accused, the accused's right to a speedy trial must be protected.

The Court reiterated that an undertrial prisoner cannot be kept in jail for an indefinite period.

The Court emphasized that the constitutional guarantee under Article 21 extends to every accused person, irrespective of the gravity of the offence.

The Court noted that the petitioner had already undergone incarceration for more than nine years without conclusion of the trial.

The Court described the situation as a gross violation of Article 21.

The Court held that prolonged detention without conclusion of trial amounts to infringement of the accused's fundamental right to personal liberty.

The Court clarified that the principles laid down in X v. State of Rajasthan (2024) must be understood in light of the facts of each individual case.

The Court observed that if an accused has remained in jail as an undertrial for over nine years, release on bail becomes necessary to safeguard constitutional rights.

Accordingly, the Court granted bail to the petitioner.

The judgment reinforces the constitutional importance of the right to a speedy trial under Article 21.

The Court emphasized that personal liberty cannot be sacrificed merely because allegations involve serious offences.

The decision recognizes that prolonged incarceration before conviction effectively punishes an accused without adjudication of guilt.

The ruling clarifies the scope of X v. State of Rajasthan (2024) and prevents its misuse as a blanket ground for denying bail.

The Court balanced societal interests in prosecuting serious crimes with the constitutional rights of accused persons.

The judgment reiterates that delay attributable to the judicial process cannot be visited upon an undertrial prisoner.

The ruling strengthens safeguards against arbitrary and excessive pre-trial detention.

The decision highlights the judiciary's responsibility to ensure that criminal trials progress within a reasonable time.

The judgment serves as a significant precedent for bail jurisprudence involving prolonged undertrial incarceration.

The ruling affirms that constitutional rights remain paramount even in cases involving grave offences such as murder.