As per case facts, the petitioner, Shubham Dhani, sought regular bail in an FIR under Section 21 of the NDPS Act, after an intermediate quantity of heroin was allegedly recovered. ... He had been involved in another NDPS case earlier and his previous bail petitions were dismissed or withdrawn. Despite the charge sheet being filed, only a few witnesses have been examined after a significant delay of about nine months, leading to his prolonged incarceration. The question arose whether the petitioner, despite prior rejections and criminal antecedents, should be granted bail given the substantial delay in trial and his extended detention. Finally, the Court held that a subsequent bail application can be considered if there's a material change in circumstances, such as the prosecution's inability to conclude evidence and the long period of incarceration. Emphasizing the fundamental right to a speedy trial under Article 21, the Court ruled that an accused cannot face unending detention. While criminal antecedents are relevant, they may not justify denying bail in cases of long incarceration and delayed trials, leading to the petitioner being granted bail.