Moti Lal Saraf vs State Of Jammu & Kashmir & Another

The Supreme Court held that the right to a speedy trial is an essential part of the fundamental right to life and liberty under Article 21 of the Constitution. The Court found that the prosecution of the appellant under Section 5(2) of the Jammu & Kashmir Prevention of Corruption Act was invalid due to lack of proper sanction, as the sanctioning authority was not competent to remove the appellant from service. Consequently, the Court upheld the High Court's decision to quash the proceedings against the appellant, emphasizing that a valid sanction is a prerequisite for prosecution under the Act.