In Sahil Manoj Machare v. State of Maharashtra, the Supreme Court reaffirmed that the right to speedy trial is a fundamental right under Article 21 of the Constitution. The accused was charged with murder under Section 302 read with Section 34 IPC and had remained in custody since November 2022. Despite charges being framed in 2024, no witness had been examined, showing complete stagnation of the trial. The Court observed that prolonged incarceration without progress in trial amounts to violation of personal liberty and cannot be justified merely because the offence is serious. It clarified that gravity of offence alone is not an absolute ground to deny bail. The Bench emphasized that undertrial detention should not become a form of punishment before conviction. Considering the systemic delay and absence of trial progress, the Court set aside the Bombay High Court’s order and granted bail, reinforcing the constitutional principle of “bail not jail” where delay threatens fairness and liberty.