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Uday Mohanlal Acharya vs State Of Maharashtra on 29 March, 2001

In Uday Mohanlal Acharya vs. State of Maharashtra (2001) 5 SCC 453, a Three Judge Bench of this Court considered the meaning of the expression "if already not availed of" used by this court in the decision rendered in case of Sanjay Dutt and held in para 48 and held that if an application for bail is filed before the charge sheet is filed, the accused could be said to have availed of his right under Section 167(2) even though the Court has not considered the said application and granted him bail under Section 167(2) Cr.P.C. This is quite evident if one refers para 13 of the reported decision as well as conclusion of the Court at page 747.
Supreme Court of India Cites 17 - Cited by 324 - B N Agrawal - Full Document

Sunjay Datt vs State (Ii) on 9 September, 1994

"21. There is yet another aspect of the matter. The right under Section 167(2) of Cr.P.C. to be released on bail on default if charge sheet is not filed within 90 days from the date of first remand is not an absolute or indefeasible right. The said right would be lost if charge sheet is filed and would not survive after the filing of the charge sheet. In other words, even if an application for bail is filed on the ground that charge sheet was not filed within 90 Davinder Kumar 2014.03.28 10:29 I attest to the accuracy and integrity of this document CRM-M-7927-2014 6 days, but before the consideration of the same and before being released on bail, if charge sheet is filed, the said right to be released on bail would be lost. After the filing of the charge sheet, if the accused is to be released on bail, it can be only on merits. This is quite evident from Constitution Bench decision of this Court in Sanjay Dutt vs. State (1994) 5 SCC 410 [Paras 48 and 53(2)(b)]. The reasoning is to be found in paras 33 to 49. This principle has been reiterated in the following decisions of this Court :
Supreme Court of India Cites 46 - Cited by 92 - J S Verma - Full Document

Sadhwi Pragyna Singh Thakur vs State Of Maharashtra on 23 September, 2011

In the face of observations made by the Apex Court in Sadhwi Pragyna Singh Thakur's case (supra), I find myself unable to be persuaded with the submissions by counsel for the petitioner that the petitioner is entitled to statutory bail even if the charge sheet had been filed by the prosecution subsequent to his filing the application for grant of bail. It is pertinent to mention that counsel for the petitioner has not addressed this Court at all and did not claim bail on merits.
Supreme Court of India Cites 39 - Cited by 94 - J M Panchal - Full Document
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