KHATRI AND OTHERS vs STATE OF BIHAR & ORS.

The Supreme Court held that the right to free legal services is an essential component of reasonable, fair, and just procedure under Article 21 of the Constitution of India. The State has a constitutional obligation to provide legal aid to indigent accused persons at all stages of the legal process, including when first produced before a magistrate. The Court emphasized that magistrates must inform accused individuals of their right to free legal services, ensuring that this right is not merely theoretical. The judgment reiterated the principles established in Hussainara Khatoon v State of Bihar [1979] 3 S.C.R. 532, and mandated strict adherence to the requirement of producing arrested persons before a magistrate within 24 hours of arrest.