Supreme Court of India on Quashing of Proceedings on ground of delay in initiation of criminal proceedings/filing criminal complaint under Artilce 21 of Constitution of India held that
While it is true that cases covered by statutory bar of limitation may be liable to be quashed without any further enquiry, cases not covered by statutory bar can be quashed on ground of delay in filing of criminal complaint in appropriate cases.
In such cases, question for consideration is, whether there is violation of right of speedy trial, which has been held to be part of Art. 21 of Constitution, having regard to nature of offence, extent of delay, person responsible for delay and other attending circumstances.
However, mere delay in completion of proceedings, may not be, by itself, a ground to quash proceedings, where offences are serious but court, having regard to conduct of parties, nature of offence and extent of delay in facts and circumstances of given case, may quash proceedings in exercise of jurisdiction under S. 482 CrPC, in the interest of justice and to prevent abuse of process of court.
[Sirajul v. State of U.P., (2015) 9 SCC 201]