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Vipul Shital Prasad Agarwal vs State Of Gujarat & Anr on 6 November, 2012

On reading and re-reading the decision of the Apex Court in Vipul Sheetal case (supra), which was not brought to my notice in the course of hearing the bail applications, the impugned bail orders passed by me are contrary to the law laid down by the Apex Court therein. Conducting further investigation cannot be tantamount to re-investigation or fresh investigation of the case. It must not be overlooked that the charge-sheet already filed is very alive and kicking, and mere conducting of further investigation of the case by the police on the direction of Court or otherwise does not have the effect of setting at naught the charge-sheet already filed against the respondents. It may be noted that the bail applications of the respondents had been considered by me on the touchstone of sub-section (2) of Section 167, CrPC and not on merits. Though the cancellation of bail necessarily involves the review of the decision already, which cannot normally be done in view of the embargo imposed by Section 362, CrPC, the power of the same Court to cancel the bail which was granted contrary to law or of the law laid down by the Apex Court cannot be negated, more so, when a superior court can always cancel the bail illegally granted by the subordinate courts. Since charge-sheet had already been filed against the respondents before the trial court before the expiry of 90 days, the mere undertaking of further investigation of the same FIR by the police cannot mean that the charge-sheet already submitted U/s 173(2), CrPC stood abandoned or rejected. Inevitably, the respondents could not be held to be entitled to statutory bail at all when this Court passed the impugned bail orders, which is liable to be cancelled.
Supreme Court of India Cites 17 - Cited by 21 - A Kabir - Full Document

Indian Bank vs M/S Satyam Fibres (India} Pvt.Ltd on 9 August, 1996

In the instant case, I had held that following the direction by the learned Sessions Judge, Karimganj upon the police to carry out further investigation of Badarpur P.S. Case No. 81/2011 U/s 302/120-B, IPC and Sections 25(1-B)(a)/27 Arms Act corresponding to Sessions Case No. 182/2012, which, in turn, was based upon the direction of this Court, the charge-sheet submitted in connection therewith earlier had become infructuous and 1. Cril. Misc. Case No. 226/13 Page 8 of 9 2. Cril. Misc. Case No. 227/13 3. Cril. Misc. Case No. 228/13 that the respondents were deemed to have been detained in custody for more than 90 days without submission of the charge-sheet by the police.
Supreme Court of India Cites 17 - Cited by 391 - S S Ahmad - Full Document

Prakash Kadam & Etc. Etc vs Ramprasad Vishwanath Gupta & Anr on 13 May, 2011

He also relies on the decisions of the Apex Court in Indian Bank v. Satyam Fibres (India) Ltd., (1996) 5 SCC 550 and Prakash Kadam and others v. Ramprasad Vishwanath Gupta and another, (2011) 6 SCC 189 to fortify his submissions. Mr. M. Biswas, the learned counsel for the accused-respondents supports the bail orders and submits that there is no provision under the law for cancelling the bail already granted except on the ground of misuse or likelihood of the bail. According to the learned counsel, if the contention of the learned counsel for the applicants is accepted, the order cancelling the bail will amount to reviewing an order which is barred by Section 362, CrPC. He also submits that when similarly situated co-accused (Abdul Basit, s/o Rashid Ali) was granted bail by this Court in Bail Appln. No. 3478/12, there is absolutely no reason to cancel the bail of the petitioners. He, therefore, submits that no substantial ground has been made out by the applicants for cancellation fof the bail granted to the accused-respondents.
Supreme Court of India Cites 7 - Cited by 141 - M Katju - Full Document
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