▪️ Principle: No Blanket Protection*
The Supreme Court held that anticipatory bail should not operate as blanket immunity against all future actions and investigations.
◾ *Bhadresh Bipinbhai Sheth v. State of Gujarat (2015)*
▪️ Principle: Gravity Alone Not Sufficient*
The Court held that the seriousness of allegations alone cannot be a sole ground for rejecting anticipatory bail. Courts must evaluate all surrounding circumstances.
◾ *Sushila Aggarwal v. State (NCT of Delhi) (2020)*
▪️ Principle: No Fixed Time Limit*
A Constitution Bench held that anticipatory bail need not be restricted by a fixed time limit and may continue until the conclusion of trial unless specifically limited by the court.
📌 *III. Interim Bail Cases*
◾ *Rambalak Singh v. State of Bihar (1966)*
▪️ *Principle: Interim Bail in Habeas Corpus Matters*
The Court recognized the power of High Courts to grant interim bail in appropriate habeas corpus proceedings to safeguard personal liberty.
◾ *Lavesh v. State (NCT of Delhi) (2012)*
▪️ *Principle: Proclaimed Offenders Not Entitled to Protection*
The Supreme Court held that a proclaimed offender or absconder is generally not entitled to anticipatory or interim bail protection.
◾ *Rohit Tandon v. Directorate of Enforcement (2018)*
▪️ *Principle: Compassionate Grounds*
Interim bail was granted considering humanitarian and compassionate circumstances.
◾ *State of Uttar Pradesh v. Gayatri Prasad Prajapati (2020)*
▪️ *Principle: Medical Grounds for Interim Bail*
The Court recognized that interim bail may be granted where the accused's medical condition requires temporary release.
◾ *Mohammad Azam Khan v. State of U.P. (2022)*
▪️ *Principle: Prolonged Incarceration*
Interim relief was granted after considering the long period of custody undergone by the accused.
◾ *Bhairaram Saraswat v. State of Maharashtra (2024)*
▪️ *Principle: Violation of Arrest Procedures*
The Court granted bail after finding procedural irregularities and violations in the arrest process.
◾ *Mohd. Tahir Hussain v. State of NCT of Delhi (2025)*
▪️ *Principle: Electoral Participation During Custody*
The Court considered the issue of electoral participation while in custody and granted appropriate interim relief based on the facts of the case.
📌 *Top 10 Bail Cases Every Criminal Lawyer Should Know*
1. State of Rajasthan v. Balchand (1977)
2. Gudikanta Narasimhulu v. Public Prosecutor (1978)
3. Babu Singh v. State of U.P. (1978)
4. Hussainara Khatoon v. State of Bihar (1979)
5. Gurbaksh Singh Sibbia v. State of Punjab (1980)
6. K.L. Verma v. State (1996)
7. Siddharam Satlingappa Mhetre v. State of Maharashtra (2010)
8. Sanjay Chandra v. CBI (2012)
9. Nikesh Tarachand Shah v. Union of India (2017)
10. Sushila Aggarwal v. State (NCT of Delhi) (2020).