MOTI LAL SARAF vs STATE OF JAMMU & KASHMIR

The Supreme Court held that Article 21 guarantees the right to a speedy trial as an essential part of the right to life and liberty. The Court found that the appellant, a Manager at the State Bank of India, was not a public servant under Section 21 of the Ranbir Penal Code, and thus, the prosecution under Section 5(2) of the Jammu & Kashmir Prevention of Corruption Act was invalid due to lack of proper sanction. Consequently, the Court quashed the proceedings against the appellant, emphasizing that a valid sanction is a prerequisite for prosecution under the Act.