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Bhukya Raju vs. The State Of Andhra Pradesh

Final Order
Court:High Court, Andhra Pradesh
Judge:Hon'ble Lalitha Kanneganti
Case Status:Dismissed
Order Date:20 Jan 2021
CNR:APHC010000192021

AI Summary

Justice Lalitha Kanneganti dismissed an anticipatory bail petition filed by accused persons in a case involving alleged illegal transportation of black jaggery and rock candy under the Andhra Pradesh Excise Act and Prohibition Act. The court held that since the petitioners had already been served with notice under Section 41-A Cr.P.C, they must follow the prescribed legal procedure and cannot seek pre-arrest bail at this stage.

Ratio Decidendi:
When notice under Section 41-A Cr.P.C has been served on the accused directing them to appear before the Station House Officer, a petition for anticipatory bail cannot be entertained at that stage. The accused must follow the prescribed legal procedure, and the police cannot apprehend them without seeking permission from the concerned Magistrate.
Obiter Dicta:
The court's observation that the petitioners were not cooperating with the investigation suggests that non-cooperation with police investigation may be a relevant factor in considering anticipatory bail petitions, though this was not the primary basis for dismissal.

Case Identifiers

Primary Case No:Criminal Petition No. 2 of 2021
Case Type:Criminal Petition
Case Sub-Type:Anticipatory Bail under Section 438 Criminal Procedure Code
Secondary Case Numbers:202100000022021, APHC010000192021, Filing Number 3/2021, Registration Number 2/2021
Order Date:2021-01-20
Filing Year:2021
Court:Andhra Pradesh High Court
Bench:Single Bench
Judges:Hon'ble Lalitha Kanneganti

Petitioner's Counsel

Paturi Srinivas Chowdary
Advocate - Appeared

Respondent's Counsel

Public Prosecutor
Public Prosecutor - Appeared

eCourtsIndia AITM

Brief Facts Summary

On September 21, 2020, at approximately 10:00 a.m., the Sub Inspector of Police at Chillakallu Police Station, Krishna District, was conducting a vehicle check based on credible information. During this check, a Tata Manza car bearing registration number AP28 CE 0027 was stopped. Upon seeing the police, the occupants of the car attempted to escape but were apprehended. The police seized 10 bags of black jaggery (each weighing 50 kilograms) and one bag of rock candy from the vehicle. The petitioners were alleged to have committed offenses under Section 34-A of the Andhra Pradesh Excise Act, 1968, Section 7(A) of the Andhra Pradesh Prohibition Act, and the GUR Regulation Order. Notice under Section 41-A Cr.P.C was subsequently served on the petitioners directing them to appear before the Station House Officer, but they did not cooperate with the investigation.

Timeline of Events

2020-09-21

Police conducted vehicle check and seized 10 bags of black jaggery (50 kg each) and one bag of rock candy from Tata Manza car bearing number AP28 CE 0027; occupants attempted to escape and were apprehended

2020-09-21 onwards

Crime No. 894 of 2020 registered at Chillakallu Police Station; petitioners alleged to have committed offenses under Section 34-A Andhra Pradesh Excise Act 1968, Section 7(A) Andhra Pradesh Prohibition Act, and GUR Regulation Order

Before 2021-01-02

Notice under Section 41-A Cr.P.C served on petitioners directing them to appear before Station House Officer; petitioners did not cooperate with investigation

2021-01-02

Criminal Petition No. 2 of 2021 filed seeking anticipatory bail; case registered and filed in Andhra Pradesh High Court

2021-01-04

First hearing before Justice Lalitha Kanneganti; case listed as interlocutory bail petition

2021-01-11

Second hearing; case continued as interlocutory

2021-01-18

Third hearing; case listed for final hearing on anticipatory bail

2021-01-20

Final hearing and order; anticipatory bail petition dismissed by Justice Lalitha Kanneganti

Key Factual Findings

Notice under Section 41-A Cr.P.C was served on the petitioners

Source: Recited from Respondent Pleading

Petitioners were directed to appear before the Station House Officer

Source: Recited from Respondent Pleading

Petitioners are not cooperating with the investigation

Source: Recited from Respondent Pleading

Police seized 10 bags of black jaggery and one bag of rock candy from the vehicle

Source: Recited from Prosecution Case

Occupants of the car attempted to escape when they saw the police

Source: Recited from Prosecution Case

Primary Legal Issues

1.Whether anticipatory bail should be granted under Section 438 Cr.P.C when notice has already been served under Section 41-A Cr.P.C
2.Whether the petitioners were falsely implicated in the case or whether there is sufficient material to proceed with investigation
3.Whether the petitioners' non-cooperation with investigation affects their eligibility for anticipatory bail

Secondary Legal Issues

1.Specificity of allegations against the petitioners
2.Procedure to be followed by police when notice under Section 41-A Cr.P.C has been issued
3.Authority of police to apprehend accused without Magistrate's permission after issuing Section 41-A notice

Questions of Law

Can anticipatory bail be granted when notice under Section 41-A Cr.P.C has already been served? Answer: No, at this stage the petition cannot be entertained.
What procedure must be followed after issuing notice under Section 41-A Cr.P.C? Answer: Police must follow the procedure as per law and cannot apprehend without seeking permission of the concerned Magistrate.

Statutes Applied

Code Of Criminal Procedure
Section 438
Provision for grant of bail in anticipatory cases; the court held that when notice under Section 41-A has been served, the petition for pre-arrest bail cannot be entertained at that stage
Code Of Criminal Procedure
Section 41-A
Notice to be served on accused before arrest; the court emphasized that once such notice is issued, the police must follow the prescribed procedure and cannot apprehend without Magistrate's permission
Andhra Pradesh Excise Act
Section 34-A
Offense related to illegal possession or transportation of excisable goods; petitioners were alleged to have committed this offense
Andhra Pradesh Prohibition Act
Section 7(A)
Offense under prohibition laws; petitioners were alleged to have violated this section

Petitioner's Arguments

The learned counsel for the petitioners argued that: (1) Omnibus allegations have been made against the petitioners without attributing any specific overt acts to them; (2) The petitioners have been falsely implicated in the case; (3) The allegations are vague and do not establish individual culpability.

Respondent's Arguments

The learned Public Prosecutor submitted that: (1) The petitioners along with others were already served with notice under Section 41-A Cr.P.C; (2) They were directed to appear before the Station House Officer; (3) The petitioners are not cooperating with the investigation; (4) The police have followed the prescribed procedure and the petitioners cannot evade the legal process.

Court's Reasoning

The court reasoned that once the police have issued notice under Section 41-A Cr.P.C to the petitioners, they must follow the procedure as per law. The court held that without seeking permission of the concerned Magistrate, the police cannot apprehend the petitioners. Therefore, at the stage when notice has already been served, the petition for grant of pre-arrest bail cannot be entertained. The court did not find it appropriate to grant anticipatory bail when the prescribed legal procedure for notice and appearance has already been initiated.

Statutory Interpretation Method:
Literal interpretation of Section 438 and Section 41-A Cr.P.CProcedural interpretation emphasizing the sequence and requirements of criminal procedure
Judicial Philosophy Indicators:
  • Emphasis on adherence to prescribed legal procedure
  • Respect for the investigative process and police authority within legal bounds
  • Caution against premature grant of anticipatory bail when statutory procedures are available
Order Nature:Procedural
Disposition Status:Disposed
Disposition Outcome:Dismissed

Impugned Orders

Chillakallu Police Station
Case: Crime No. 894 of 2020
Date:

Specific Directions

  1. 1.Petition for grant of pre-arrest bail cannot be entertained at this stage
  2. 2.All pending miscellaneous applications shall stand closed

Precedential Assessment

Persuasive (Other High Court)

This is a single bench decision of the Andhra Pradesh High Court on a procedural matter regarding anticipatory bail. While it does not establish binding precedent outside Andhra Pradesh, it provides persuasive authority on the interpretation of Section 438 and Section 41-A Cr.P.C and the proper stage at which anticipatory bail petitions should be entertained. The decision clarifies the procedural requirements that must be followed when notice under Section 41-A has been served.

Tips for Legal Practice

1.Anticipatory bail petitions should not be entertained after notice under Section 41-A Cr.P.C has been served; the accused must follow the prescribed procedure of appearing before the police and seeking bail if arrested
2.Non-cooperation with investigation after being served with notice under Section 41-A may be viewed unfavorably by courts in bail considerations
3.Police must follow proper procedure and seek Magistrate's permission before arresting an accused after serving Section 41-A notice; failure to do so may provide grounds for bail or other relief

Legal Tags

Anticipatory bail petition dismissal under Section 438 Criminal Procedure CodeSection 41-A notice procedure and its effect on bail eligibilityAndhra Pradesh Excise Act violations and criminal prosecutionPolice procedure and Magistrate permission requirements for arrestNon-cooperation with investigation as factor in bail considerationIllegal transportation of jaggery and excisable goodsAndhra Pradesh Prohibition Act enforcement and criminal liabilityHigh Court jurisdiction in anticipatory bail mattersProcedural requirements in criminal bail applicationsTiming and stage of anticipatory bail petitions in criminal procedure

Disclaimer: eCourtsIndia (ECI) is not a lawyer and this analysis is generated by ECI AI, it might make mistakes. This is not a legal advice. Please consult with a qualified legal professional for matters requiring legal expertise.

Order Issued After Hearing

Purpose:

Disposed

Before:

Hon'ble Lalitha Kanneganti

Listed On:

20 Jan 2021

Order Text

THE HON'BLE SMT. JUSTICE LALITHA KANNEGANTI CRIMINAL PETITION No.2 of 2021

ORDER:

This petition is filed under Section 438 of Code of Criminal Procedure, 1973 (for short "Cr.P.C") seeking pre-arrest bail to the petitioners/A-1 and A-2 in the event of their arrest in connection with Crime No.894 of 2020 on the file of Chillakallu Police Station, Krishna District, wherein the petitioners are alleged to have committed the offence punishable under Section 34-A of A.P. Excise Act, 1968; Section 7 (A) of Andhra Pradesh Prohibition Act and GUR Regulation Order of Rules.

  1. The case of the prosecution is that on 21.09.2020 at about 10.00 a.m. on credible information while the Sub Inspector of Police, Chillakallu Police Station was conducting the vehicle check found one Tata Manza Car bearing No.AP28 CE 0027 and on seeing the police, inmates of the car tried to escape, they were apprehended and the police seized 10 bags of each 50 KGs of black jaggery and one bag of rock candy from their possession.

  2. Heard Sri P.Srinivasa Choudary, learned counsel for the petitioners and learned Public Prosecutor for the respondent-State.

  3. Learned counsel for the petitioners would submit that omnibus allegations are made against the petitioners and no specific overt acts are attributed to the petitioners and they were falsely implicated in this case.

  4. On the other hand, learned Public Prosecutor submits that the petitioners along with others were already served with notice

under Section 41-A of Cr.P.C and they were directed to appear before the Station House Officer, but they are not cooperating with the investigation.

  1. When once the police have issued the notice under Section 41-A of Cr.P.C to the petitioners, they have to follow the procedure as per law and without seeking permission of the concerned Magistrate, the police cannot apprehend the petitioners. Hence, at this stage the petition for grant of pre-arrest bail cannot be entertained.

  2. In the result, the criminal petition is dismissed.

As a sequel, all the pending miscellaneous applications shall stand closed.

___________________________ LALITHA KANNEGANTI, J

20th January, 2021 PVD

THE HON'BLE SMT. JUSTICE LALITHA KANNEGANTI

DISMISSED

CRIMINAL PETITION No.2 of 2021

20th January, 2021

PVD

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Order(1) - 20 Jan 2021

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