In Brief
This case addresses a critical conflict in Indian criminal law: whether anticipatory bail under Section 438 of the Code of Criminal Procedure should have a fixed time limit. The Supreme Court found two opposing schools of thought among its own benches. One line of cases (relying on the Constitution Bench's Sibbia decision) says anticipatory bail continues indefinitely. The other line says it must be time-limited, requiring accused persons to seek regular bail after the investigation is complete. The Court found that even Sibbia does not clearly resolve this question and referred the matter to a larger Bench for authoritative settlement on whether bail duration should be capped at a fixed period and when it should end.
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