BASHIRA vs STATE OF U.P.

The Supreme Court held that the belated appointment of counsel for the appellant, charged under Section 302 IPC for murder, violated his right to adequate legal representation as mandated by Rule 37 of the General Rules (Criminal) 1957 and Article 21 of the Constitution. The Court emphasized that the rule requires sufficient time for counsel to prepare, and failure to comply with this requirement vitiated the trial. Consequently, the Court found a breach of Article 21, leading to the conclusion that the conviction was invalid due to inadequate legal aid.