The SC in the case of Pankaj Kumar v. State of Maharastra, AIR 2008 SC 3077 held that "the right to speedy trial in all criminal persecutions is an inalienable right under Article 21 of the Constitution. This right is applicable not only to theactual proceedings in court but also includes within its sweep the preceding police investigations as well. The right to speedy trial extends equally to all criminal persecutions and is not confined to any particular category of cases."