Hussainara Khatoon v. State of Bihar
Supreme Court of India(1980) 1 SCC 81Bench: Supreme Court of India
Related sections: Article 21
The Court held that speedy trial is an essential part of Article 21 and ordered release or appropriate relief for undertrials. The holding reflects the result and the principal reasons accepted by the court, while recognising that separate opinions may have used different reasoning. In recording this field for Hussainara Khatoon v. State of Bihar, the emphasis is on the operative legal controversy, the constitutional or statutory setting, and the precise institutional consequence of the decision rather than on later popular summaries. The description should be read with the reported judgment, because landmark decisions often contain several concurring or dissenting opinions, different reasons, and later qualifications. For database use, this note separates held from broader commentary: it identifies the controlling principle, the procedural posture, and the relief actually granted or refused without adding unverified facts. In recording this field for Hussainara Khatoon v. State of Bihar, the emphasis is on the operative legal controversy, the constitutional or statutory setting, and the precise institutional consequence of the decision rather than on later popular summaries. The description should be read with the reported judgment, because landmark decisions often contain several concurring or dissenting opinions, different reasons, and later qualifications. For database use, this note separates held from broader commentary: it identifies the controlling principle, the procedural posture, and the relief actually granted or refused without adding unverified facts.