Monday 4 November 2024

Bombay HC declares arrest illegal as grounds of arrest were communicated to accused’s wife but not to the accused

We have heard the learned counsel for the petitioner as

well as the learned APP for the State and after going through

the reply affidavit and the documents annexed with the reply

affidavit, we do not find any grounds of arrest being

communicated to the petitioner. From the arrest panchanama

it is evident that, information is given to his wife on the cell

number provided by him, apart from which, there are no

grounds of arrest mentioned in the arrest surrender form. 

{Para 6}

7. It is the requirement of Section 50 of the Cr.P.C. that an

accused, who is being arrested without warrant to be forthwith

communicated about the full particulars of the offence for

which he is arrested or the other grounds for such arrest. The

petitioner has alleged non-compliance of Section 50 of the

Cr.P.C. as also Article 22(1) of the Constitution of India, by

relying upon law laid down by the Apex Court in this regard.

Therefore, it is a specific contention of the petitioner that,

there is a violation of his constitutional as well as statutory

rights.

8. After considering the submissions as well as the

documents produced on record, we do not find grounds of

arrest being communicated to the petitioner as contemplated

by Section 50 of the Cr.P.C. and explained by this Court as well

as the Hon’ble Apex Court in its various judicial

pronouncements. We are satisfied that there is a flagrant

violation of Section 50 of the Cr.P.C. as well as Article 22(1) of

the constitution of India, and since the grounds of arrest are

not communicated to the petitioner, making his arrest illegal.

  IN THE HIGH COURT OF JUDICATURE AT BOMBAY

CRIMINAL APPELLATE JURISDICTION

WRIT PETITION (STAMP) NO.17029 OF 2024

Sachin Mahipati Nimbalkar Vs  The State of Maharashtra

CORAM: BHARATI DANGRE &

 MANJUSHA DESHPANDE, JJ.

 DATED : 23rd OCTOBER, 2024

Order : (Per Manjusha Deshpande, J.):-

1. The petitioner is seeking a declaration that his arrest in

relation to FIR No.1191 of 2023 dated 31.10.2023, registered

at Karad City Police Station, Satara is illegal and in gross

violation of the fundamental rights guaranteed to him under

Article 21 and 22 of the Constitution of India. He is further

seeking a declaration that the consequential remand order

dated 01.11.2023 and all the subsequent remand orders

passed by the learned J.M.F.C., Karad, are null and void and

are in violation of fundamental rights guaranteed to him under

the Constitution of India.

2. The petitioner has been arraigned as an accused in C.R.

No. 1191 of 2023, for offence punishable under Sections 302,

364, 324, 323, 143, 147, 148, 149, 504 and 506 of the Indian

Penal Code. Though initially he was not named as an accused,

but during the course of investigation, name of the petitioner

came to be added as an accused. He was arrested on

01.11.2023 at 12:41 p.m. and was produced before the J.M.F.C,

Karad on the very day. He was remanded to police custody till

06.11.2023, and thereafter his police custody remand was

extended upto 07.11.2023. Investigating Agency has fled

charge-sheet in the present matter.

A complaint was lodged by one Pramod Vishwas Pawar

alleging that, his brother Pravin had an affair with the

daughter of one Balasaheb Pawar. On 30.10.2023, one Shekhar

Pawar and four other unknown persons came inquiring the

whereabouts of the brother of the complainant Pravin and

when the complainant informed that he was not aware about

his brother’s whereabouts, Shekhar assaulted the complainant

and made the complainant sit in a Bolero car. It is further

alleged that, there was another four wheeler, wherein the

father of the complainant and one Janardhan Gurav had sat

alongwith two other persons. The accused persons assaulted

Janardhan, the complainant and his father with sticks, fsts

and blows and due to the said assault, Janardhan has expired.

Therefore the FIR was lodged in Karad City Police Station on

31.10.2023.

3. The petitioner had fled the regular Bail Application,

which is pending before the Additional Sessions Judge, Karad.

The petitioner is challenging his arrest in the present Writ

Petition on the ground that, the grounds of arrest were not

informed to him in writing and as such his arrest is in gross

violation of the constitutional mandate under Article 22(1) of

the Constitution of India, and there is total non-compliance of

Section 50 of the Code of Criminal Procedure, 1973.

4. It is the contention of the petitioner that, mere passing of

successive remand orders do not validate initial remand, if

such arrest was not in conformity with law. The grounds of

arrest ought to have been furnished to the petitioner before

producing him before the learned J.M.F.C., Karad, seeking

custody and subsequent remand. The continuing custody of

the petitioner is grossly illegal and a nullity, since the initial

arrest itself is in violation of constitutional mandate and is in

flagrant violation of statutory rights of the petitioner.

The learned counsel for the petitioner has relied on the

judgment delivered by the Hon’ble Apex Court in case of

Pankaj Bansal V/s. Union of India and Ors. 2023 SCC OnLine 1244.

 and the other various judgments of this Court as well as the Hon’ble Apex Court in support of his contention.


5. The learned APP representing the State has relied on the

affdavit affrmed by Mr. Rajesh Prakash Mali, the Assistant

Police Inspector, attached to Karad City Police Station, Satara,

wherein he has candidly stated that, during the course of

investigation, the petitioner was arrested on 01.11.2023 at

12:41 hours, since his name was revealed in the investigation.

He was informed about the grounds of his arrest and the said

fact has also been mentioned in the station diary dated

01.11.2023, maintained in Karad City Police Station.

It is further stated that, the concerned API has followed

guidelines of the Hon’ble Apex Court in case of D. K. Basu V/s.

State of West Bengal by informing the wife of the petitioner

about arrest of the petitioner on her mobile phone. Arrest

panchanama to that effect was made and the same was signed

by the panchas. After conducting necessary medical

examination the petitioner was produced within 24 hours

before the Court of J.M.F.C, Karad, alongwith the copy of

remand report. The petitioner was given the copy of remand

report, which has been acknowledged by him by putting his

signature, therefore there is no violation of his fundamental

rights as claimed by the petitioner. According to the API,

before the arrest of the petitioner, reasons for arrest and his

legal rights have been explained to the petitioner in presence

of panchas and, accordingly, the arrest form of the petitioner

was duly flled up. Therefore according to the API, the

guidelines of the Hon’ble Apex Court in case of D. K. Basu

(supra) have been complied with.

It is further stated in the affdavit that, informing the

2 (1997) 1 SCC 416


particulars of offence to the accused is the statutory as well as

the constitutional requirement, the same is complied by way of

fling remand application before the court, a copy of which has

also been served on the accused and his lawyer.

6. We have heard the learned counsel for the petitioner as

well as the learned APP for the State and after going through

the reply affdavit and the documents annexed with the reply

affdavit, we do not find any grounds of arrest being

communicated to the petitioner. From the arrest panchanama

it is evident that, information is given to his wife on the cell

number provided by him, apart from which, there are no

grounds of arrest mentioned in the arrest surrender form.

So far as ground being communicated through the

remand application is concerned, the law in this regard is now

well settled. The Hon’ble Apex Court in case of Prabir

Purkayastha V/s State (NCT of Delhi) 2024 SCC OnLine SC 934

 has elaborately

considered this issue and in para 49 of the said decision, the

distinction between the “reasons of arrest” and “grounds of

arrest” have been culled out, which reads thus :

“49. It may be reiterated at the cost of repetition that

there is a significant difference in the phrase ‘reasons

for arrest’ and ‘grounds of arrest’. The ‘reasons for

arrest’ as indicated in the arrest memo are purely

formal parameters, viz., to prevent the accused person

from committing any further offence; for proper

investigation of the offence; to prevent the accused

person from causing the evidence of the offence to

disappear or tempering with such evidence in any

manner; to prevent the arrested person for making

inducement, threat or promise to any person

acquainted with the facts of the case so as to dissuade

him from disclosing such facts to the Court or to the

Investigating Offcer. These reasons would commonly

apply to any person arrested on charge of a crime

whereas the ‘grounds of arrest’ would be required to

contain all such details in hand of the Investigating

Offcer which necessitated the arrest of the accused.

Simultaneously, the grounds of arrest informed in

writing must convey to the arrested accused all basic

facts on which he was being arrested so as to provide

him an opportunity of defending himself against

custodial remand and to seek bail. Thus, the ‘grounds of

arrest’ would invariably be personal to the accused and

cannot be equated with the ‘reasons of arrest’ which are

general in nature.”

7. It is the requirement of Section 50 of the Cr.P.C. that an

accused, who is being arrested without warrant to be forthwith

communicated about the full particulars of the offence for

which he is arrested or the other grounds for such arrest. The

petitioner has alleged non-compliance of Section 50 of the

Cr.P.C. as also Article 22(1) of the Constitution of India, by

relying upon law laid down by the Apex Court in this regard.

Therefore, it is a specifc contention of the petitioner that,

there is a violation of his constitutional as well as statutory

rights.

8. After considering the submissions as well as the

documents produced on record, we do not find grounds of

arrest being communicated to the petitioner as contemplated

by Section 50 of the Cr.P.C. and explained by this Court as well

as the Hon’ble Apex Court in its various judicial

pronouncements. We are satisfied that there is a flagrant

violation of Section 50 of the Cr.P.C. as well as Article 22(1) of

the constitution of India, and since the grounds of arrest are

not communicated to the petitioner, making his arrest illegal.

Resultantly, the Writ Petition is allowed and we declare

that the arrest of the petitioner in relation to FIR No. 1191 of

2023 dated 31.10.2023 is illegal and in gross violation of

fundamental rights of the petitioner and the consequential

remand order dated 01.11.2023 passed by the J.M.F.C., Karad

as well as the subsequent remand orders are null and void.

In view of the declaration, the petitioner deserves to be

released forthwith from the custody on furnishing bail bond to

the satisfaction of the trial Court. The Writ Petition is disposed

off in the above terms.

We must clarify that the observations made in the

present Writ Petition would not effect the merits of the case,

but are restricted to the claim raised by the petitioner about

the illegality of the arrest.

(MANJUSHA DESHPANDE, J.) (BHARATI DANGRE, J.)


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