The Supreme Court has held that the right to a speedy trial is not the exclusive prerogative of an accused and that a victim of an offence also has the legal right to seek expeditious disposal of criminal proceedings.

A Bench of Justice Ujjal Bhuyan and Justice Atul S. Chandurkar set aside a Delhi High Court order that had dismissed a complainant’s petition seeking an expedited trial as frivolous and imposed costs of ₹10,000 on her.

The Supreme Court held that a victim is a stakeholder in the criminal justice system and has the locus standi to approach the High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), seeking directions for expeditious completion of the trial.

Victim Is a Stakeholder in Criminal Justice System

The case arose from an FIR registered under Section 420 of the Indian Penal Code, 1860. Following the investigation, a chargesheet was filed and the matter was registered before the Judicial Magistrate First Class.

Aggrieved by the delay in the proceedings, the complainant had earlier approached the Delhi High Court, which directed the trial court to conclude the proceedings within two years after the framing of charges.

As the trial made little progress, she again approached the High Court under Section 528 of the BNSS, seeking directions for expeditious disposal.

The prosecution questioned her locus standi to maintain such a petition. Accepting this objection, the High Court held that in a State prosecution, the complainant’s role was limited to being a witness and that only the State or the accused could institute such proceedings. It dismissed her plea as frivolous and imposed costs of ₹10,000.

Right to Speedy Trial Is Not Limited to Accused

Disagreeing with the High Court, the Supreme Court emphasised that a victim cannot be treated merely as a witness in criminal proceedings. A victim or the victim’s legal guardian is a definite stakeholder in the criminal justice system and is entitled to seek a fair and speedy trial.

The Bench observed:

“To say that the role of the victim is limited to being a witness, is not correct. A victim or the legal guardian of the victim is a definite stakeholder in the criminal justice system. Like the accused, she has also a vested right to insist on a speedy trial and also for a fair trial.”

The Court further held that a victim can approach the High Court under Section 528 BNSS for a direction to the trial court to expedite the proceedings.

High Court's Order Describing Plea as Frivolous Set Aside

The Supreme Court held that the High Court was not justified in characterising the complainant’s petition as frivolous or as a drain on the judiciary’s already overburdened docket.

It observed that the High Court’s decision was based on a misreading of the relevant legal and constitutional provisions and could not be sustained.

The Bench also took note of the State’s submission that 22 witnesses had been cited for the prosecution, one of whom had been deleted. Accordingly, 21 prosecution witnesses remained, and the first prosecution witness was undergoing cross-examination.

The Supreme Court directed the trial court to conclude the proceedings expeditiously, within an outer limit of one year from September 24, 2026. The appeal was allowed and the costs imposed on the complainant were set aside.

Reliance on Earlier Supreme Court Ruling

The Bench also relied on its recent judgment in Keshvendra Singh v. Shankar Singh, reported as 2026 LiveLaw (SC) 815, which recognised that the right to a speedy trial is not merely the prerogative of the accused but is also a valuable right of the victim.

The ruling reinforces the principle that victims have an independent stake in ensuring that criminal proceedings are conducted fairly and without undue delay.

Case Title: Renuka Jain v. State of NCT of Delhi & Ors.
Citation:- 2026 INSC 1100
Bench: Justice Ujjal Bhuyan and Justice Atul S. Chandurkar