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Supreme Court of India 2021-05-12 dismissed

GAUTAM NAVLAKHA vs NATIONAL INVESTIGATION AGENCY

Bench: 2 — Uday Umesh Lalit, K.M. Joseph

In Brief

The Supreme Court dismissed the appeal of human rights activist Gautam Navlakha against denial of default bail. Navlakha was arrested on charges under the UAPA and IPC in August 2018 but was placed under house arrest by the Delhi High Court following its stay of a transit remand order. He later sought default bail claiming the 34 days of house arrest, along with subsequent police and judicial custody, exceeded the 90-day threshold. The Court held that while house arrest constituted actual deprivation of liberty, it was not ordered purportedly under Section 167 of the CrPC and therefore could not be counted towards the statutory default bail period. The Court distinguished between actual deprivation of liberty and custody legally authorized under Section 167, finding that the house arrest lacked the requisite statutory moorings.

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Criminal Procedure Default Bail Detention and Custody Habeas Corpus Constitutional Rights Police Custody Judicial Custody House Arrest Unlawful Activities Prevention Act Preventive Detention Prison Overcrowding Protection of Liberty Interrogation Rights

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