ValkyaEditorial

Bail & Arrest — 45 Valkya Editorial digests

The law on bail and arrest — anticipatory bail, default (statutory) bail, the safeguards around arrest under Article 22 and the BNSS, and the special bail regimes under the PMLA and UAPA. Close digests of the judgments that govern when liberty must be granted and when custody is justified.

Supreme CourtSupreme Court of India

Baksish Ahmad v. Union of India (2026): a CAPF member may invoke the Delhi High Court's writ jurisdiction though the cause of action arose elsewhere

On 9 June 2026 the Supreme Court held that a member of the Central Armed Police Forces, including the BSF, may invoke the Delhi High Court's writ jurisdiction under Article 226(1) in a service matter on the strength of the situs of the Union of India and the force headquarters in Delhi, notwithstanding that the cause of action arose outside that High Court's territory. The doctrine of forum non conveniens, the Court held, will rarely apply where a constitutional remedy is pursued under clause (1) of Article 226.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

Mohtashem Billah Malik v. Sana Aftab (2026): welfare of the child is paramount but not the sole factor in custody

In a cross-border custody dispute over two minor sons, the Supreme Court set aside the High Court's 'welfare alone' approach. The Court held that while the child's welfare is paramount, financial capacity, standard of living, comfort and education of the children — and the conduct of the parents — are all relevant. The matter was remanded for fresh consideration.

Valkya Editorial··6 min
Supreme CourtSupreme Court of India

SVT v. CA (2026): psychological testing of children in custody disputes only on demonstrable necessity

The Supreme Court held that psychological or psychiatric evaluation of children in custody and visitation disputes is not barred, but is permissible only on demonstrable necessity, with minimum intrusion, institutional neutrality and proportionality, the child's welfare paramount. Courts must distinguish therapeutic care from adversarial evaluation and guard against parental-alienation dynamics.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

Seesa Santosh v. State of Telangana (2026): the right to travel abroad bows to the complainant's right to a speedy trial

A two-judge Bench of the Supreme Court held that an accused's wish to seek medical treatment abroad under Article 21 is not absolute and must yield to the complainant's right to a speedy trial where comparable facilities exist in India. A digest of the facts, the balancing test, and why the High Court's permission to travel was set aside.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

Surekha Domaji Bele v. MSEDCL (2026): after a vitiated inquiry is remanded, the disciplinary authority must apply its mind afresh to punishment

The Supreme Court partly allowed an electricity-company clerk's appeal, holding that once a defective departmental inquiry is set aside and misconduct is later proved on fresh evidence, the disciplinary authority cannot mechanically fall back on the old, pre-remand show-cause notice and reimpose dismissal — it must independently apply its mind to the quantum of punishment. A digest of the facts, the holding on proportionality and natural justice, and what it means for service-law practice.

Valkya Editorial··7 min
High CourtHigh Court of Karnataka

Shipoil Ltd v. M.T. Standorf (2025): admiralty jurisdiction, not the Commercial Court

In January 2025 the Karnataka High Court rejected an application to return a vessel-recovery petition to the Commercial Court, holding that maritime claims under the Admiralty (Jurisdiction and Settlement of Maritime Claims) Act 2017 belong to the High Court's admiralty side. A digest of the facts, the forum question, and the lex specialis reasoning.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

BCCI v. Cricket Association of Bihar (2016): the Lodha reforms and the writ jurisdiction over the Board

In 2016 a three-judge Bench of the Supreme Court accepted the Justice R.M. Lodha Committee's recommendations and directed the BCCI to implement sweeping structural reforms. A digest of the two-judgment litigation born of the 2013 IPL betting scandal, the holding that the Board performs public functions amenable to Article 226, and how several reforms were later relaxed.

Valkya Editorial··9 min
High CourtHigh Court of Uttarakhand at Nainital

Rampal v. State of Uttarakhand: a POCSO conviction on 'no evidence at all'

The Uttarakhand High Court suspended a POCSO conviction and granted bail, terming the trial-court verdict 'more than shocking' — this was not a case of insufficient evidence but of no evidence at all, with the victim hostile and forensics unconnected to the accused.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

United Bank of India v. Satyawati Tondon: writ self-restraint in SARFAESI matters

On 26 July 2010 a two-judge bench of the Supreme Court held that the High Court should not ordinarily entertain a writ petition under Article 226 challenging measures taken under the SARFAESI Act 2002 where the borrower has an efficacious statutory remedy before the Debts Recovery Tribunal under Section 17. The alternative-remedy rule is self-imposed judicial restraint, applied with 'greater rigour' in tax, cess and bank-recovery matters. The Bench castigated the routine grant of interim relief in such writ petitions and held that the High Court was 'wholly unjustified' in entertaining the writ at the Section 13(4) stage.

Valkya Editorial··14 min
LandmarkSupreme Court of India

L. Chandra Kumar v. Union of India: judicial review as basic structure and the limits of administrative tribunals

On 18 March 1997 a seven-judge Constitution Bench of the Supreme Court, in a unanimous judgment authored by Chief Justice A.M. Ahmadi, struck down clause 2(d) of Article 323A and clause 3(d) of Article 323B to the extent they excluded the writ jurisdiction of the High Courts and of the Supreme Court over decisions of administrative tribunals. Judicial review under Articles 32, 226 and 227 was held to be part of the basic structure of the Constitution, tribunals were repositioned as courts of first instance rather than substitutes for High Courts, and the 'alternative institutional mechanism' theory of S.P. Sampath Kumar (1987) was partly overruled.

Valkya Editorial··15 min
Supreme CourtSupreme Court of India

Munna Moyuddin Shaikh v. State of Gujarat: modifying a life sentence to time served after twenty-three years in custody

On 26 May 2026, a Supreme Court bench of Justices K.V. Viswanathan and Vijay Bishnoi modified a life sentence to the period already undergone by the appellant — a man who had spent over twenty-three years in custody without remission. The judgment reaffirms the settled position that the imposition of a life sentence does not bar modification to a fixed-term sentence where the convict has already undergone more than 14 years of imprisonment, and reads against the architecture of remission and pre-mature release under the criminal-justice system.

Valkya Editorial··7 min
Supreme CourtSupreme Court of India

Prem Prakash v. Directorate of Enforcement: how the Supreme Court reaffirmed 'bail is the rule' under the PMLA

On 28 August 2024, the Supreme Court granted bail to Prem Prakash — an associate of the then-Chief Minister of Jharkhand — in a Prevention of Money Laundering Act, 2002 matter, after he had spent over a year in custody. The judgment reaffirmed the constitutional principle that 'bail is the rule, jail is the exception' in PMLA cases, held statements made by an accused while in PMLA custody to be inadmissible against him under Section 50 PMLA, and continued the post-Vijay Madanlal arc in which the Court has moderated the operation of the twin bail conditions where prolonged incarceration meets the proportionality test of liberty. A digest of the holding, the doctrinal frame, and where the PMLA bail line stands now.

Valkya Editorial··8 min
Supreme CourtSupreme Court of India

State of West Bengal v. Committee for Protection of Democratic Rights: the constitutional ceiling on Section 6 of the DSPE Act

On 17 February 2010, a five-judge Constitution Bench of the Supreme Court — Balakrishnan CJ, Raveendran, D.K. Jain (authoring for the unanimous Bench), Sathasivam and Panchal JJ — held that the writ jurisdiction of the High Courts under Article 226 and of the Supreme Court under Article 32 is plenary and constitutional, and that a High Court may direct the Central Bureau of Investigation to investigate a cognisable offence within a State even without the State's consent under Section 6 of the Delhi Special Police Establishment Act 1946. Judicial review is part of the basic structure; the constitutional power cannot be fettered by ordinary legislation. But the power is to be exercised sparingly and in exceptional cases, to preserve federal balance. A close reading of the judgment, the underlying Garbeta incident, and the federalism architecture the Bench was working through.

Valkya Editorial··14 min
Supreme CourtSupreme Court of India

Vijay Madanlal Choudhary v. Union of India: how the Supreme Court upheld the PMLA arrest, attachment, and twin bail conditions

On 27 July 2022, a three-judge bench led by Justice A.M. Khanwilkar upheld substantially all the contested provisions of the Prevention of Money Laundering Act, 2002 — the arrest power under Section 19, the provisional attachment power under Section 5, the search-and-seizure architecture under Section 17, the reverse-burden provision under Section 24, and the twin bail conditions under Section 45. The judgment also held that an Enforcement Case Information Report (ECIR) is not equivalent to an FIR and need not be supplied to the accused. A digest of the holdings, the doctrinal contributions, and the review now pending.

Valkya Editorial··8 min
Weekly Report

BNSS one year on: bail, custody, default release, trial in absentia, and the s.482 discretion

A year into the operation of the Bharatiya Nagarik Suraksha Sanhita, 2023, the practitioner-level architecture is now substantially visible. The Supreme Court's April 2026 disposition in Narayan v. State of Madhya Pradesh settled the s.480(3) bail-condition question. Section 187(3)'s fragmentary-custody architecture has produced a competing High Court line — the Kulkarni interpretation against the Senthil Balaji line — without a definitive Article 141 resolution. The s.482 discretion has widened, on the Chhattisgarh High Court's reading. Trial in absentia under s.356, the s.183 recording-of-statements architecture, and the s.367–369 protective regime for accused with intellectual disability have each produced their own developing doctrine. This piece reads the year's jurisprudence as one practitioner architecture.

Valkya Editorial··11 min
Weekly Report

Weekly Report: The BNSS bail framework, one year on

As the Bharatiya Nagarik Suraksha Sanhita completes its first year in force, the early picture on bail, default bail and police-station procedure is taking shape. A practitioner's scan of where the new Code has settled and where it has not.

Valkya Editorial··3 min
High CourtChhattisgarh High Court

Section 482 BNSS and the wider anticipatory-bail discretion: a Chhattisgarh High Court reading

Section 482 of the BNSS replaced Section 438 of the CrPC on 1 July 2024, but did so without reproducing the statutory guiding factors — nature of accusation, antecedents, possibility of fleeing — that the CrPC had attached. A reading of the Chhattisgarh High Court's diagnosis of what this means for the anticipatory-bail discretion, and how trial courts and the bar should approach the post-BNSS framework.

Valkya Editorial··9 min