Sunday, 26 May 2024

Whether the court should release accused on bail if he is arrested in breach of S 41A of CRPC?


 The arrest on 23.12.2022 was not on the basis of any additional material discovered in the course of the investigation, but was based on the same material which was within the knowledge of the Investigating Officer at the time of issuance of notice under Section 41A. Such routine arrest without application of mind and due regard to the law amounts to an abuse of power and does not satisfy the requirement of Section 41A(3) Cr.P.C. {Para 30}

31. To sum up, the Investigating agency has not been able todemonstrate existence of circumstances or supportive material on the basis of which the decision to arrest was taken. Absence of

such circumstances, information or material which is the sine qua non for the decision of arrest reduces the provision a dead letter and renders the arrest illegal.

33. Under the circumstances, and for the reasons supra, the arrest of the petitioners is held to be illegal for breach of mandatory provision under Section 41A Cr.P.C. Hence the petition is allowed in terms of prayer clause (b). The Interim bail granted by order dated 9.1.2023 is confirmed.

IN THE HIGH COURT OF JUDICATURE AT BOMBAY

CRIMINAL APPELLATE JURISDICTION

WRIT PETITION NO. 378 OF 2023 WITH

INTERIM APPLICATION NO. 804 OF 2023

Chanda Kochhar Vs Central Bureau of Investigation

CORAM : ANUJA PRABHUDESSAI, &

N. R. BORKAR, JJ.

DATED : 6th FEBRUARY, 2024.

1. By this Petition under Article 226 of the Constitution of India,

the petitioners seek to:

(i) quash the FIR No. RCBDI/2019/E/0001 dated 22.01.2019

registered under Section 120 B and Section 420 of the Indian Penal

Code and Section 7 and 13(2) r/w. 13(1)(d) of the prevention of

Corruption Act, 1988.

(ii) quash arrest of the petitioners being in violation of settled tenets

of law under Section 46 and 41A (3) of Cr.P.C. and

(iii) to quash the remand order dated 24.12.2022 and subsequent

orders passed by the learned Special Judge, CBI.

2. The brief facts necessary to decide this petition are as under.


 On 8.12.2017, CBI registered preliminary inquiry bearing No.

PE.BDI/2017/E0001 in view of the information that during the

period from 2009 to 2012, the officials of ICICI Bank had

sanctioned credit facilities/ high value loan to the Videocon Group

of Companies promoted by Venugopal Dhoot, in violation of the

Banking Regulation Act under RBI guidelines and the credit policy

of the Bank. The petitioner Chanda Kochhar was one of the

members of the sanctioning committee. It is alleged that as a part

of quid pro quo, Mr. Dhoot made investment of Rs.64 Crores in

NuPower Renewables Pvt. Ltd. (NRPL) through M/s. Supreme

Energy Private Limited (SEPL), and also to Pinnacle Energy Trust

managed by the petitioner Deepak Kochhar, through circuitous

route. It is also alleged that the flat at CCI Chambers owned by

theVideocon Group was sold to the family trust of Deepak Kochhar

for Rs.11 lakhs, though the value of the flat was Rs.5.25 Crores.

3. The preliminary inquiry revealed that the petitioner Chanda

Kochhar had abused her official position in sanctioning loan to M/s.

VIEL and got illegal gratification through her husband Deepak

Kochhar. The finding of the preliminary inquiry led to registration

of the FIR against the petitioners for the aforesaid offences.


4. The petitioners were issued notice dated 27.06.2022 under

Section 41A of Cr.P.C., pursuant to which they appeared before the

Investigating Officer on 8.7.2022 and were duly interrogated. The

petitioners were placed under arrest on 23.12.2022, when they had

appeared before the Investigating Officer for interrogation pursuant

to notice dated 15.12.2022 issued under Section 41A of the Cr.P.C.

The petitioners were produced before the learned Special Judge for

remand. By order dated 24.12.2022, and subsequent remand

orders, the learned CBI Special Judge remanded the petitioners

initially to police custody and later to judicial custody. Hence,

these petitions for the reliefs, as stated above.

5. By order dated 09.01.2023 the co-ordinate bench of this

Court released the petitioner on interim bail mainly on the ground

that the arrest was in contravention of the mandatory provisions of

Section 41A Cr.P.C. The said order has been challenged by the

CBI before the Apex Court in Special Leave to Appeal (Cri.) Nos.

13697-13698/2023. By order dated 03.01.2024, the Hon’ble

Supreme Court directed this Court to hear the main writ petition

which was fixed for hearing before this Court on 05.01.2024, with

further directions to the parties not to ask for adjournment on the

said date. In view of the said directions, the petitions were taken

up for final hearing.

6. On 05.01.2024, Mr. Amit Desai, learned Senior Counsel for

the petitioner made a statement that the petitioners do not wish to

press the prayer clause (a) which relates to quashing of the FIR. The

challenge is restricted to the legality of the arrest as well as the

remand orders. The challenge is mainly on the ground of violation

of mandatory provisions of Section 41A, 46 & 50 of Cr.P.C.

7. Mr. Amit Desai, learned Sr. Counsel representing the

Petitioner submits that the arrest of the petitioner is in violation of

the mandatory provisions under Section 41A of Cr.P.C. He submits

that the petitioners had co-operated with the investigation right from

the time of the preliminary inquiry. The petitioners had complied

with the terms of the notice under Section 41A of the Cr.P.C. and

furnished the requisite information. The petitioner Chanda Kochhar

had sought to produce detail notes prepared by her, however, the

same were not accepted and she was not allowed to make it part of

the statement.

8. Mr. Desai, learned Senior Counsel submits that both the

petitioners had also co-operated with the other investigating agency

i.e. Enforcement |Directorate ( ED) investigating offences under

PMLA. They were interrogated and their statements were recorded

on several dates. Hence, the contention that the petitioners have not

been co-operating is baseless. Even otherwise, the petitioners have

right to remain silent and their silence cannot be construed as noncooperation.

9. Learned counsel for the petitioner submits that the

adjudicating authority vide detail order dated 06.11.2020 had

accepted the explanation given by the petitioner and held that the

properties alleged to be illegal gratification were not proceeds of

crime and lifted the provisional attachment order passed by the E.

D. This Court (Coram : Prakash Naik J.) while considering the bail

application of Deepak Kochhar has set out in detail the explanation

given by the petitioner in the course of the investigation and

granted bail to Deepak Kochhar. The challenge to the said order

has been dismissed by the Apex Court. The Investigating Agency

failed to consider this material aspect while placing the petitioner

under arrest. As regards confrontation of the petitioners and the co-

accused Venugopal Dhoot, to investigate the allegation of quid pro

quo, learned Senior Counsel submits that these allegations were

within the knowledge of the investigating agency, despite which the

petitioners and the co-accused were not interrogated for over three

years. This aspect has been considered by this Court in Writ Petition

No.300 of 2023 filed by Venugopal Dhoot. Learned Counsel further

submits that even after the arrest of the petitioners, the co-accused

Venugopal Dhoot was served with notice under Section 41-A,

making it appear that his presence was not required for

confrontation.

10. Learned Senior Counsel further submits that ‘reason to

believe’ cannot be the mere ipse dixit of the investigating officer.

There must be rational and reasonable justification as to the need to

effect arrest. In the present case, the arrest is made in routine

manner, without reasonable satisfaction and without satisfying the

requirements of Section 41 of Cr. P.C.

11. Mr. Desai submits that the petitioners were arrested a few

weeks before the marriage of their son, which fact makes it evident

that the arrest was malafide. The arrest was not based on any

material evidence and was in contravention of Section 41A(3)

Cr.P.C as well as the provisions under Section 46 of the Cr. P.C. He

submits that the remanding Court also failed to consider this aspect

and thereby failed to comply with the duties and obligation as

required under the dictum of the Apex Court in Arnesh Kumar v.

State of Bihar (2014) 8 SCC 273. Reliance has been placed on

several decisions, including the decision in Satendar Kumar Antil

v. CBI null(2022) 10 SCC 51; Arnesh Kumar vs. State of BiharArnesh Kumar vs. State of Bihar

(supra); Santosh v. State of Maharashtra (2017) 9 SCC 714;

Joginder Kumar vs. State of U.P. (1994) 4 SCC 260; Arnab

Goswami vs. State of Maharashtra 9(2021) 2 SCC 427; Daulat

Samirmal Mehta v. Union of India 2021 SCC Online Bom. 200.

12. Per contra, Mr. Kuldeep Patil, learned Counsel for the

respondent CBI submits that there is no violation of the provisions

under Section 41A (3). He contends that the case diary records the

reasons for the arrest. He submits that several complex issues are

involved in the matter and that the co-accused V.N.Dhoot had not

given satisfactory answers. Hence they were required to be

confronted with each other. He submits that the Court cannot go

into the sufficiency of the material and cannot substitute its

objective opinion for the subjective satisfaction. He further submits

that the first remand report submitted before the Special Judge

incorporated the reasons. The Special Judge had also perused the

case dairy and only upon being satisfied with the reasons recorded

in the case diary, the Special Judge had passed the remand order.

13. Mr. Kuldip Patil, learned Counsel for CBI contends that the

arrest of the petitioner Chanda Kochhar was effected in presence of

a woman constable Sarita Kumari, which fact is also reflected in the

personal search memo as well as the case dairy. The arrest was

effected before the sunset, and hence the decisions in Kavita and

Alexandar (supra) are not applicable. He further submits that the

grounds of arrest were informed to the petitioners and even

otherwise the petitioners were well aware of the charges leveled

against them. He submits that the respondent CBI has followed the

legal mandate, as well as the procedural safeguards, hence the arrest

cannot be considered to be illegal.

14. We have perused the records and considered the submissions

advanced by the learned Counsel for the respective parties.

15. The legality of arrest is challenged essentially for non-compliance of the mandate of Section 41A Cr.P.C. which reads

thus:

“ 41A- Notice of appearance before police officer:

(1) The Police Officer shall in all cases where the

arrest of a person is not required under the provisions

of sub-section (1) of Section 41, issue a notice

directing the person against whom a reasonable

complaint has been made, or credible information

has been received, or reasonable suspicion exists that

he has committed a cognizable offence, to appear

before him or at such other place as my be specified

in the notice.

(2) Where such a notice is issued to any person, it

shall be the duty of that person to comply with the

terms of the notice.

(3) Where such person complies and continues to

comply with the notice, he shall not be arrested in

respect of the offence referred to in the notice, unless

for the reasons to be recorded, the police officer is of

the opinion that he ought to be arrested.

(4) Where such person, at any time, fails to comply

with the terms of the notice or is unwilling to

identify himself, the police officer may, subject to

such orders as may have been passed by a

Competent Court in this behalf, arrest him for the

offence mentioned in the notice.”

16. Section 41A was inserted to avoid routine arrests. This

section mandates issuance of notice ‘where the arrest of a person is

not required under Sub Section (1) of Section 41. This provision

casts an obligation on such person to comply with the provision and

further restricts the power to arrest when such person complies or

continues to comply with the terms of notice, unless the police

officer is of the opinion that the arrest is necessary, and further

mandates to record to reasons for the arrest.

17. In Satyendra Kumar Antil (supra) the Apex Court has

observed that Sections 41 and 41A are facets of Article 21 of the

Constitution of India, and the Investigating Agencies and their

officers are duty bound to comply with the mandate of the said

provisions as well as the directions issued in Arnesh Kumar vs.

State of Bihar (2014) 8 SCC 273. The relevant paras of Satyendra

Kumar Antil read thus:

“24. This provision mandates the police officer to

record his reasons in writing while making the arrest.

Thus, a police officer is duty-bound to record the

reasons for arrest in writing, Similarly, the police

officer shall record reasons when he/she chooses not to

arrest. There is no requirement of the aforesaid

procedure when the offence alleged is more than seven

years, among other reasons.


25. The consequence of non-compliance with Section

41 shall certainly enure to the benefit of the person

suspected of the offence. Resultantly, while considering

the application for enlargement on bail, courts will

have to satisfy themselves on the due compliance of this

provision. Any non-compliance would entitle the

accused to a grant of bail.

26. Section 41A deals with the procedure for

appearance before the police officer who is required to

issue a notice to the person against whom a reasonable

complaint has been made, or credible information has

been received or a reasonable suspicion exists that he

has committed a cognizable offence, and arrest is not

required under Section 41(1). Section 41B deals with

the procedure of arrest along with mandatory duty on

the part of the officer.

27. On the scope and objective of Section 41 and

41A, it is obvious that they are facets of Article 21 of

the Constitution. We need not elaborate any further, in

light of the judgment of this Court in Arnesh Kumar v.

State of Bihar, (2014) 8 SCC 273:

“7.1. From a plain reading of the aforesaid provision,

it is evident that a person accused of an offence

punishable with imprisonment for a term which may be

less than seven years or which may extend to seven

years with or without fine, cannot be arrested by the

police officer only on his satisfaction that such person

had committed the offence punishable as aforesaid. A

police officer before arrest, in such cases has to be

further satisfied that such arrest is necessary to prevent

such person from committing any further offence; or

for proper investigation of the case; or to prevent the

accused from causing the evidence of the offence to

disappear; or tampering with such evidence in any

manner; or to prevent such person from making any

inducement, threat or promise to a witness so as to

dissuade him from disclosing such facts to the court or

the police officer; or unless such accused person is

arrested, his presence in the court whenever required

cannot be ensured. These are the conclusions, which

one may reach based on facts.

7.2. The law mandates the police officer to state the

facts and record the reasons in writing which led him to

come to a conclusion covered by any of the provisions

aforesaid, while making such arrest. The law further

requires the police officers to record the reasons in

writing for not making the arrest.

7.3. In pith and core, the police officer before arrest

must put a question to himself, why arrest? Is it really

required? What purpose it will serve? What object it

will achieve? It is only after these questions are

addressed and one or the other conditions as

enumerated above is satisfied, the power of arrest

needs to be exercised. In fine, before arrest first the

police officers should have reason to believe on the

basis of information and material that the accused has

committed the offence. Apart from this, the police

officer has to be satisfied further that the arrest is

necessary for one or the more purposes envisaged by

sub-clauses (a) to (e) of clause (1) of Section 41 CrPC.

8. An accused arrested without warrant by the police

has the constitutional right under Article 22(2) of the

Constitution of India and Section 57 CrPC to be

produced before the Magistrate without unnecessary

delay and in no circumstances beyond 24 hours

excluding the time necessary for the journey:

8.1. ........................…

8.2. Before a Magistrate authorises detention under

Section 167 CrPC, he has to be first satisfied that the

arrest made is legal and in accordance with law and all

the constitutional rights of the person arrested are

satisfied. If the arrest effected by the police officer does

not satisfy the requirements of Section 41 of the Code,

Magistrate is duty-bound not to authorise his further

detention and release the accused. In other words,

when an accused is produced before the Magistrate, the

police officer effecting the arrest is required to furnish

to the Magistrate, the facts, reasons and its conclusions

for arrest and the Magistrate in turn is to be satisfied

that the condition precedent for arrest under Section 41

CrPC has been satisfied and it is only thereafter that he

will authorise the detention of an accused.

8.3. The Magistrate before authorising detention will

record his own satisfaction, may be in brief but the said

satisfaction must reflect from his order. It shall never be

based upon the ipse dixit of the police officer, for

example, in case the police officer considers the arrest

necessary to prevent such person from committing any

further offence or for proper investigation of the case

or for preventing an accused from tampering with

evidence or making inducement, etc. the police officer

shall furnish to the Magistrate the facts, the reasons

and materials on the basis of which the police officer

had reached its conclusion. Those shall be perused by

the Magistrate while authorising the detention and only

after recording his satisfaction in writing that the

Magistrate will authorise the detention of the accused.

9. ...The aforesaid provision makes it clear that in all

cases where the arrest of a person is not required under

Section 41(1) CrPC, the police officer is required to

issue notice directing the accused to appear before him

at a specified place and time. Law obliges such an

accused to appear before the police officer and it

further mandates that if such an accused complies with

the terms of notice he shall not be arrested, unless for

reasons to be recorded, the police officer is of the

opinion that the arrest is necessary. At this stage also,

the condition precedent for arrest as envisaged under

Section 41 CrPC has to be complied and shall be

subject to the same scrutiny by the Magistrate as

aforesaid.

10. ..................…

11. Our endeavour in this judgment is to ensure that

police officers do not arrest the accused unnecessarily

and Magistrate do not authorise detention casually and

mechanically. In order to ensure what we have

observed above, we give the following directions:

11.1. All the State Governments to instruct its police

officers not to automatically arrest when a case under

Section 498-A IPC is registered but to satisfy

themselves about the necessity for arrest under the

parameters laid down above flowing from Section 41

CrPC;

11.2. All police officers be provided with a check list

containing specified sub-clauses under Section 41(1)(b)

(ii);

11.3. The police officer shall forward the check list duly

filled and furnish the reasons and materials which

necessitated the arrest, while forwarding/producing the

accused before the Magistrate for further detention;

11.4. The Magistrate while authorising detention of the

accused shall peruse the report furnished by the police

officer in terms aforesaid and only after recording its

satisfaction, the Magistrate will authorise detention;

11.5. The decision not to arrest an accused, be

forwarded to the Magistrate within two weeks from the

date of the institution of the case with a copy to the

Magistrate which may be extended by the

Superintendent of Police of the district for the reasons

to be recorded in writing;


11.6. Notice of appearance in terms of Section 41-A

CrPC be served on the accused within two weeks from

the date of institution of the case, which may be

extended by the Superintendent of Police of the district

for the reasons to be recorded in writing;

11.7. Failure to comply with the directions aforesaid

shall apart from rendering the police officers

concerned liable for departmental action, they shall

also be liable to be punished for contempt of court to

be instituted before the High Court having territorial

jurisdiction.

11.8. Authorising detention without recording reasons

as aforesaid by the Judicial Magistrate concerned shall

be liable for departmental action by the appropriate

High Court.

12. We hasten to add that the directions aforesaid shall

not only apply to the cases under Section 498-A IPC or

Section 4 of the Dowry Prohibition Act, the case in

hand, but also such cases where offence is punishable

with imprisonment for a term which may be less than

seven years or which may extend to seven years,

whether with or without fine.”

28. We only reiterate that the directions aforesaid ought

to be complied with in letter and spirit by the

investigating and prosecuting agencies, while the view

expressed by us on the non-compliance of Section 41

and the consequences that flow from it has to be kept in

mind by the Court, which is expected to be reflected in

the orders.

29. Despite the dictum of this Court in Arnesh Kumar

(supra), no concrete step has been taken to comply with

the mandate of Section 41A of the Code. This Court has

clearly interpreted Section 41(1)(b)(i) and (ii) inter alia

holding that notwithstanding the existence of a reason to

believe qua a police officer, the satisfaction for the need

to arrest shall also be present. Thus, sub-clause (1)(b)(i)

of Section 41 has to be read along with sub-clause (ii)

and therefore both the elements of ‘reason to believe’ and

‘satisfaction qua an arrest’ are mandated and

accordingly are to be recorded by the police officer.

30 ...…

31 ....…

32. We also expect the courts to come down heavily on

the officers effecting arrest without due compliance of

Section 41 and Section 41A. We express our hope that

the Investigating Agencies would keep in mind the law

laid down in Arnesh Kumar (Supra), the discretion to be

exercised on the touchstone of presumption of innocence,

and the safeguards provided under Section 41, since an

arrest is not mandatory. If discretion is exercised to

effect such an arrest, there shall be procedural

compliance. Our view is also reflected by the

interpretation of the specific provision under Section 60A

of the Code which warrants the officer concerned to

make the arrest strictly in accordance with the Code.


100. In conclusion, we would like to issue certain

directions. These directions are meant for the

investigating agencies and also for the courts.

Accordingly, we deem it appropriate to issue the

following directions, which maybe subject to State

amendments.:

100.1...................…

100.2 The investigating agencies and their officers are

duty-bound to comply with the mandate of Section 41

and 41A of the Code and the directions issued by this

Court in Arnesh Kumar (supra). Any dereliction on

their part has to be brought to the notice of the higher

authorities by the court followed by appropriate action.

100.3 The courts will have to satisfy themselves on the

compliance of Section 41 and 41A of the Code. Any

non-compliance would entitle the accused for grant of

bail.” (emphasis supplied)

18. The scope and ambit of Section 41 and 41A as well as the

dictum of the Apex Court in Satyender Kumar Antil, Arnab

Goswami etc was considered by the co-ordinate Bench of this Court

while granting interim bail to the petitioners for non compliance of

the mandate of Section 41A. We are conscious of the fact that the

interim order does not substantially decide the rights, liability or lis

between the parties and that the interim order is always subject to

the final order, which will adjudicate the final rights and liabilities

of the parties. Hence, there can be no gainsaying that the prima

facie observation or tentative view expressed at interim stage is not

binding at the final adjudication.

19. Nevertheless, a perusal of order dated 09.01.2023 reveals that

while considering the plea for interim bail pending final disposal of

the petition, this Court referred to the relevant provisions under

Section 41, 41A, 60 and 60A and relying upon the principles

enunciated by the Apex Court in Satyendra Kumar Antil, Arnab

Goswami, Santosh, Joginder Kumr, Mohd Zuben and considered

whether the petitioners arrest being contrary to the mandate of law

i.e. whether the arrests are in violation of Section 41, 41A and 60A

of Cr.P.C., the petitioners are entitled to be released on bail.

20. In this regard it was observed that it is always open for a

Court to examine whether the reason for formation of the belief

have a rational connection with a formation of the belief that there

was direct live link between the material before the Officer and the

formation of the belief. Upon examining the grounds of arrest, as

recorded in the arrest memo and considering the dictum in Selvi v.

State of Karnataka (2010) 7SCC 263, it was observed thus:

“8.10. The ground for arresting the petitioners as

stated in the arrest memos is unacceptable and is

contrary to the reason(s) / ground(s) on which the

person can be arrested, that is contrary to the Mandate

of Section 41(1)(b)(ii)(a) to (e). ‘Not disclosing true

and correct facts’ cannot be the reason, inasmuch as,

the right against self-incrimination as provided for in

Article 20(3) of the Constitution”

x x x

8.21. The facts reveal that the petitioners after

registration of PE in December 2017 had reported to

the CBI, pursuant to the summons issued; tht they not

only appeared but also submitted documents, details of

which are mentioned in the seizure memos, as set-out

in the facts stated aforesaid. Admittedly, during the

period, 2019 till June 2022, for around four years,

neither any summons were issued to the petitioners nor

any communication was established by the respondent

No.1-CBI with the petitioners. On 08.07.2022, the

petitioners reported to the CBI officer, New Delhi,

pursuant to the notice issued under Section 41-A.

Thereafter, again Section 41-A notice was issued by the

CBI in December 2022, pursuant to which, the

petitioners appeared before the CBI on 23.12.2022,

when they came to be arrested. What was the reason

to arrest the petitioners after four years is not spelt out

in the arrest memos, as mandated by Section 41(1)(B)

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(ii) Cr.P.C. The reason given in the arrest memos to

arrest the petitioners, having regard to the facts as

stated aforesaid, appears to us, to be casual,

mechanical and perfunctory, clearly without

application of mind. The ground for arrest of the

petitioners mentioned in the arrest memos is in clear

breach of mandatory provisions of Section 41 and 41-A

and 60-A of Cr.P.C.

8.22. As a Constitutional Court, we cannot be

oblivious to the contravention of the mandatory

provisions of law and the judgments of the Apex Court,

in particular, the directions given in Arnesh Kumar

(Supra) and Satender Kumar Antil (Supr). It is

expected that the directions and provisions be

complied with by the concerned officers/courts, in

letter and spirit. Needless to state, that personal

liberty of an individual is an important aspect of our

constitutional mandate. Merely because an arrest can

be made because it is lawful, does not mandate that

arrest must be made. As emphasized by the Apex

Court, a distinction must be made between the

existence of the power to arrest and the justification for

exercise of it. It is further observed that if arrests are

made in a routine manner, it could cause incalculable

harm to the reputation and self-esteem of a person and

that presumption of innocence is a facet of Article 21,

which would enure to the benefit of the accused.

8.23. In the present case, the reasons recorded by

the Officer in the ground of arrest, does not satisfy the

tests laid down in Section 41(1)(b)(ii)(a) to (e) of

Cr.P.C. for the reasons set out hereinabove. It does

not disclose as to whether the arrest was necessary for

one or more purpose (s) as envisaged in the said

provision. The same is also in contravention of the

directions given by the Apex Court in Arnesh Kumar

(Supra), in particular, the direction stipulated in para

11.2 and 11.3. …

8.24 Accordingly, in the facts, we hold that the

petitioners’ arrest is not in accordance with law.

Thus, non-compliance of the mandate of Section 41(1)

(b)(ii), Section 41-A and Section 60-A of Cr.P.C. will

enure to the benefit of the petitioners, warranting their

release on bail. ...”

21. As regards the legality of the remand order, the co-ordinate

bench of this Court has observed that the concerned Judge

authorizing detention ought to have recorded its own satisfaction,

may be in brief, but the satisfaction must be reflected from his

order. It was observed that the order of remand does not confirm to

the said requirement/direction given by the Apex Court in the case

of Arnesh Kumar, this Court held that the petitioners are entitled for

bail, pending hearing and final disposal of the petitions.

22. The aforesaid observations recorded in order dated 9.1.2023,

while considering the question “whether the arrest of the petitioner

was illegal”, cannot be considered as prima facie observations or

tentative view. It needs to be borne in mind that as on the date of

the order, the challenge to the FIR was also pending before the

Court. The said prayer has been deleted subsequent to the order

dated 09.01.2023. In such circumstances, the findings recorded in

Order dated 09.01.2023 cannot be construed as tentative view or

prima facie observations solely for the reason that the Court had

granted interim bail.

23. Be that as it may, the only other material which has now been

placed before us is the case dairy which purportedly records the

reasons of arrest. A perusal of the case diary reveals that the

petitioners were served with notice dated 27.06.2022 under Section

41A for appearance on 4.7.2022. The petitioners had requested to

postpone the date to 08.07.2022 and accordingly, they appeared

before the Investigating Officer on 08.07.2022 and were duly

interrogated. In the meantime, the co-accused V.N.Dhoot was also

interrogated with respect to the allegations of quid pro qua of Rs.64

Crores and transfer of flat owned by Videocon to Quality Advisory

Trust of Deepak Kochhar.

24. On 15.12.2022, the Investigating Officer issued notices under

Section 41A to the petitioners as well as to the co-accused

V.N.Dhoot, on the ground that there were several inconsistencies in

their statements which were not satisfactorily answered and it was

necessary to call and confront them with one another for proper

investigation and for taking the case to its logical end.

25. Mr. V.N.Dhoot was interrogated on 22.12.2022, and the

petitioners had expressed their inability to appear on the scheduled

date as they had to attend the hearing of another matter listed before

this Court. The date of appearance was fixed on 23.12.2022. Both

the petitioners appeared before the Investigating Officer on

23.12.2022 at about 2.00 p.m. They were interrogated and on the

same date, at about 4.30 p.m. they were placed under arrest.

26. The reasons for the arrest as recorded in the case dairy are that

(1) The petitioners are not cooperating with the investigation (2)

their custodial interrogation is required to unearth (a) the entire

gamut of conspiracies which led to sanction of term loan of Rs.1875

Crores to financially belligerent Videocon Group of Companies

between June 2009 and April 2012,and (b) to unearth the

conspiracy hatched for creation of complex financial structure to

conceal the identity for quid pro qua of Rs.64 Crores by the

petitioner Chanda Kochhar in the company account of her husband

and transfer of flat situated at 45 CCI Chambers, valued at Rs.5.25

Crores to the family members of petitioner Deepak Kocchar for

Rs.11 Crores in the year 2016, and (3) to ascertain the names and

roles of the other conspirators /officials of ICICI Bank in

sanctioning disbursement of the term loan to Videocon Group

Companies.

27. There can be no dispute that it is within the domain of the

Investigating Agency to interrogate the accused and to arrive at a

subjective satisfaction on the issue of arrest. We are conscious and

mindful that the satisfaction of the investigating agency is

subjective in nature and the Court cannot go into the reasonableness

of the reasons of arrest and or substitute its objective opinion for


the subjective satisfaction. Nevertheless, the subjective satisfaction

is not wholly immune from judicial reviewability. The Court can

consider whether the reasons for deprivation of liberty are rational,

reasonable or fanciful. In Barium Chemicals Ltd vs. Company law

Board the Apex Court with reference to Section 237 of the

Companies Act has observed that the Court cannot go into the

question of aptness or sufficiency of the grounds upon which the

subjective satisfaction of an authority is based. However, the entire

process is not subjective. While the existence of relevant

material/information is objective, whereas drawing inference

therefrom alone is a subjective process. Only check upon the

subjective power is the existence of circumstances/material

information. In case it is established that there was no material

information or factual basis, the exercise of power becomes illegal.

It is thus within the powers of the Court to ensure that the

subjective satisfaction is on factual basis and not on the basis of the

whims or caprice of the investigating agency.

28. In the instant case, the preliminary enquiry relating to the

sanctioning of loan to the Videocon Group of Companies in

violation of Banking Regulations and Guidelines since the year

2009 to 2012 was registered in the year 2017. The petitioners

were questioned in the course of the preliminary inquiry, and

subsequently the FIR was registered on 22.01.2019. The

petitioners were named as accused in the said FIR for the alleged

offences of criminal conspiracy and cheating. Despite the gravity

of the offence, the petitioners were not interrogated or summoned

for a period of over three years from the date of registration of the

crime. They were served with notice under Section 41A dated

27.06.2022 thereby indicating that their arrest was not required in

the said crime under the provisions of sub-section (1) of Section 41

Cr.P.C. The petitioners complied with the terms of the notice and

appeared before the Investigating Officer and were duly

interrogated. Furthermore, in compliance with the notice dated

15.12.2022, under Section 41A, the petitioners appeared before the

Investigating Agency on 23.12.2022. It is on this date that they

were placed under arrest, on the ground of non co-operation and

purportedly to unearth the entire gamut of conspiracy which led to

sanctioning of term loan of Rs.1875 Crores to financially

beleaguered Videocon Group of Companies between June 2009 to

April 2012.


29. It is relevant to note that though it is within the powers of the

Investigating Agency to interrogate the accused has a right to

remain silent. The right to silence emanates from Article 20(3) of

the Indian Constitution, which gives an accused the right against

self incrimination. Suffice it to say that exercise of the right to

remain silent cannot be equated with non co-operation. Reliance is placed on the decision in Santosh Dwarkadas Fajat and Pankaj

Sansal (supra)

30. The allegations that the petitioners are involved in the

conspiracy, similarly the gravity of the offence and alleged quid pro

quo were to the knowledge of the Investigating Agency as on the

date of the registration of the FIR. The FIR states that the loan

sanctioning Committees of ICICI Bank had sanctioned loan to

Videocon Group of Companies. Some of the senior officials of

ICICI Bank were also named in the first information report, and it

was stated that the role of these senior officers of the sanctioning

committee was also required to be investigated. Thus the

involvement of the other bank officials in the conspiracy was not

discovered in the course of the investigation but were to the

knowledge of the Investigating agency, as on the date of registration

of the FIR, despite which the Investigating Agency did not feel the

need to arrest and interrogate the petitioners for a period of over

three years. The arrest on 23.12.2022 was not on the basis of any additional material discovered in the course of the investigation, but was based on the same material which was within the knowledge of the Investigating Officer at the time of issuance of notice under Section 41A. Such routine arrest without application of mind and due regard to the law amounts to an abuse of power and does not satisfy the requirement of Section 41A(3) Cr.P.C.

31. To sum up, the Investigating agency has not been able to

demonstrate existence of circumstances or supportive material on

the basis of which the decision to arrest was taken. Absence of

such circumstances, information or material which is the sine qua

non for the decision of arrest reduces the provision a dead letter and

renders the arrest illegal.

32. The petitioners have also alleged breach of Section 46 of

Cr.P.C. for the reason that the arrest of the petitioner Chanda

Kochhar was not effected by a lady police officer. Section 46

provides the mode of arreset. Sub Section 1 of Section 46 provides

that in making an arrest the police officer or other person making

the same shall actually touch or confine the body of the person to be

arrested, unless there be a submission to the custody by word or

action. Proviso to this sub section provides that where a woman is

to be arrested, unless the circumstances indicate to the contrary, her

submission to custody on an oral intimation of arrest shall be

presumed and unless the circumstances otherwise require or unless

the police officer is a female, the police officer shall not touch the

person of the woman for making her arrest. Sub Section 4

prescribes the procedure of arrest of woman after sunset and before

sunrise.

33. In the instant case, the petitioner Chanda Kochhar was

arrested before sunset. Hence, sub section (4) of Section 46 is not

attracted. The decisions relied upon are therefore distinguishable.

The case diary reveals that the arrest was in presence of a lady

police officer. There is nothing on record to prima facie indicate

that the petitioner was physically touched by a male police officer.

No complaint in this regard was made to the Judge before whom the

petitioner was produced for remand. Hence, we are of the view

that there was no contravention of Section 46 or 60A Cr.P.C.


33. Under the circumstances, and for the reasons supra, the arrest

of the petitioners is held to be illegal for breach of mandatory

provision under Section 41A Cr.P.C. Hence the petition is allowed

in terms of prayer clause (b). The Interim bail granted by order

dated 9.1.2023 is confirmed. The petitions and the interim

applications, if any, stand disposed of in above terms.

( N.R.BORKAR, J.) (ANUJA PRABHUDESSAI, J.)


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