The Supreme Court granted bail to Mohd. Saquib Ansari and Waqar Azhar, who had spent nearly 12 years in custody under the Unlawful Activities (Prevention) Act. The bench held that the prolonged incarceration without trial completion violated Article 21 of the Constitution. The court reaffirmed that the stringent bail conditions under Section 43D(5) of UAPA cannot override the fundamental right to life and personal liberty when trial delay becomes excessive and constitutionally unconscionable.

This judgment fits into a growing line of Supreme Court decisions that push back against the indefinite detention effectively created by UAPA's stringent bail provisions. Section 43D(5) of UAPA bars bail if the court, on a perusal of the case diary or chargesheet, finds prima facie grounds for believing the accusation is true. This provision has historically made bail nearly impossible in UAPA cases, as courts tend to avoid deep scrutiny at the bail stage to prevent prejudging the trial.

The critical constitutional tension here is between this legislative restriction and Article 21's guarantee of life and personal liberty. The Supreme Court in Union of India v. K.A. Najeeb (2021) had already held that constitutional courts retain inherent power to grant bail when trial delay infringes Article 21, notwithstanding UAPA's bar. The present case involving Ansari and Azhar reinforces that precedent: a 12-year delay without trial completion crosses the constitutional threshold.

For CLAT PG aspirants, the doctrinal takeaway is the interplay between special legislation and fundamental rights. Parliament can restrict ordinary bail rights through UAPA, but it cannot, per the Court, extinguish constitutional courts' supervisory power under Articles 21, 32, and 226. The question examiners love to set is: can a statutory embargo on bail override a constitutional court's Article 21 jurisdiction? The answer, consistently, is no — and this case is one more data point in that chain.