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As per case facts, an FIR (No. 89/1999) was registered against the petitioner and 34 others under the Indian Medical Council Act, 1956 and Drugs and Cosmetics Act, 1940, based
...on a Civil Surgeon's communication regarding unregistered doctors. For over 24 years, no challan was filed, hindering the petitioner's passport application. The challan was eventually filed after 25 years, but charges are un-framed. The petitioner sought quashing, citing false implication and a violation of the right to speedy trial. The question arose whether the FIR and consequential proceedings should be quashed due to inordinate, unexplained investigation delay and the statutory limitation bar under Section 468 Cr.P.C., considering the offenses' punishment terms. Finally, the High Court quashed the FIR and consequential proceedings due to the twenty-five-year unexplained delay in investigation and charge-sheet filing, and the expiry of the limitation period for cognizance under Section 468 Cr.P.C. The State's failure to justify the delay was deemed an infraction of the petitioner's Article 21 right to a speedy trial.
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