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Issues:
Delay in criminal proceedings leading to quashing, Justification for quashing based on delay, Seriousness of the offence in relation to delay, Applicability of previous judgments on delay in criminal proceedings. Analysis: The Supreme Court granted leave in a case where accused persons managed to delay criminal proceedings significantly, resulting in the quashing of the case solely due to the procrastination of court proceedings. The State of Bihar challenged the judgment of a learned single Judge of the Patna High Court who quashed the criminal proceedings. The case involved an FIR registered in 1991 under the Railway Property (Unlawful Possession) Act, 1966. The accused persons sought discharge in 1998, leading to a series of legal challenges and delays. The High Court quashed the proceedings in 1998 based on the significant delay in framing charges, which was not attributable to the accused. The Supreme Court highlighted the seriousness of the offence under the RPUP Act, emphasizing the need to consider the delay in the context of the offence's gravity. The Court noted that delay alone may not be sufficient to quash criminal proceedings, particularly in cases involving serious offences. Previous judgments were cited to illustrate the importance of balancing the delay with the nature of the offence. The Court emphasized that delays in proceedings were primarily caused by the accused challenging orders or being absent from court, rather than factors attributable to the prosecution or the court. The judgment clarified that the accused could not take advantage of delays caused by their actions. Ultimately, the Supreme Court set aside the High Court's order and directed the trial court to proceed with the case, requiring completion of prosecution evidence within six months from the accused's appearance. The Court warned that if the accused contributed to further delays, the time frame set for completion would be adjusted accordingly. The appeal was allowed on these terms, emphasizing the importance of expeditious completion of criminal proceedings while considering the nature of the offence and the actions of the accused in causing delays.
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