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Supreme Court of India 2019-02-13 allowed

THE STATE OF MAHARASHTRA vs SURENDRA PUNDLIK GADLING

Bench: 3 — Ranjan Gogoi, L. Nageswara Rao, Sanjay Kishan Kaul

In Brief

The case concerns whether an accused arrested under the Unlawful Activities (Prevention) Act is entitled to "default bail" when the State fails to file a charge-sheet or obtain proper extension of detention within prescribed periods. The respondent was arrested in connection with the Bhima Koregaon incident and alleged CPI (Maoist) involvement. The Court held that while the Public Prosecutor's report for detention extension had formal defects, it demonstrated sufficient independent application of mind through detailed grounds, scrutiny of the IO's application, and expanded reasoning. The respondents were not entitled to default bail as the substantive requirements were met. The Court emphasized that the Public Prosecutor must act as an independent safeguard, not merely rubber-stamp police requests.

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Criminal Procedure Unlawful Activities (Prevention) Act Preventive Detention Default Bail Public Prosecutor Administrative Law Constitutional Rights Liberty of Accused

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