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By Harjyot State vs . Pram Govinda @ Govinda on 10 April, 2019 cites

Kerala State Electricity Board, Etc vs S.N. Govinda Prabhu & Brothers And ... on 26 August, 1986

15. It may be pertinent to note that before the amendment introduced Section 174A IPC in the statute book, there was no offence for non appearance in the court after publication of process under Section 82 Cr.PC but a person could thereafter be arrested by FIR No. 718/18 State Vs. Pram Govinda @ Govinda 7/8 anyone at any time. However, since now an offence has been created, the ingredients of Section 82 must be strictly satisfied before an offence can be said to have been committed. Therefore, the language of Section 82 (2) (i) has to be strictly construed as also the procedure contained therein has to be treated as mandatory and not directory as it is no longer a procedural provision but directly creates liability as an offence.
Supreme Court of India Cites 26 - Cited by 61 - O C Reddy - Full Document
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