Facts: The appellant was accused of murdering his wife, Rukhmini, on 01.05.2019 by pouring petrol on her and setting her ablaze at her parental home. The prosecution's case rested on a dying declaration made by the victim, CCTV footage showing the appellant purchasing petrol, and statements from witnesses. Initially, the appellant had provided a false story claiming his in-laws were responsible for the act. Following the victim's death from 69% burn injuries, charges were framed under sections 302, 307, and 203 of the Indian Penal Code, along with relevant sections of the SC & ST Act. The appellant had been in continuous incarceration since 23.07.2019, totaling over six years and seven months, with the trial still pending and only six witnesses examined out of forty-two.Procedural Posture: This is a criminal appeal filed under section 14-A of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, challenging the order dated 10.09.2025 passed by the Special Judge, Ahmednagar, which rejected the appellant's bail application under section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023.Issue: Whether the appellant is entitled to bail solely on the grounds of prolonged pre-trial incarceration and the violation of the right to a speedy trial under Article 21 of the Constitution, despite the gravity of the murder charges?Holding: No, the court dismissed the appeal and denied bail, but directed the trial court to conclude the proceedings within six months.Reasoning: The court acknowledged that while Article 21 guarantees a speedy trial and prolonged incarceration can be a ground for bail, it must be balanced against the nature and gravity of the offence. In this case, there was strong prima facie evidence, including a dying declaration and CCTV footage, linking the appellant to a heinous crime punishable by life imprisonment or death. The court noted that although the trial was delayed, six witnesses had already been recorded. It concluded that the legal precedents cited by the appellant regarding bail for long incarceration were not applicable to the specific facts of this case. To balance the rights of the accused with the interests of justice, the court ordered a day-to-day trial to ensure conclusion within a six-month window.