In Pardeep Kumar @ Banu v. State of Punjab, the Supreme Court of India held that prolonged undertrial detention without commencement of trial violates Article 21 and may amount to punishment. The accused had been in custody for nearly two years, facing serious charges, yet the trial had not begun and no witnesses were examined. The Court emphasized that the right to speedy trial is a fundamental right under Article 21. It observed that continued incarceration without progress in trial becomes punitive and unjustified, as the accused is presumed innocent until proven guilty. While acknowledging the gravity of offences, the Court clarified that seriousness alone cannot justify indefinite detention. Where there is undue delay and no likelihood of early trial, personal liberty must prevail. Accordingly, the Court set aside the High Court’s order and granted bail, reinforcing that delay in trial can outweigh the gravity of allegations in appropriate cases.