DHARAM PAL vs STATE OF HARYANA .

The Supreme Court addressed the issue of fair trial and proper investigation under Article 21 of the Constitution, emphasizing the need for justice to be rendered without bias or indifference. The Court held that the High Court's dismissal of the appellant's plea for intervention in the investigation was erroneous, as it failed to recognize the potential for injustice due to inadequate investigation. The outcome was a remand for further consideration of the appellant's grievances regarding the investigation process.