Facts
The Appellant’s second bail application in a case involving Sections 419, 420, 467, 468, and 471 of the IPC was rejected by the Allahabad High Court
Source reference: p. 2While dismissing the bail, the High Court issued extensive directions to the Trial Court to take coercive measures and mandated that state officials (Additional Chief Secretary, DGP, etc.) implement departmental accountability systems for the service of summons, citing its previous orders in Bhanwar Singh and Jitendra v. State of U.P.
Source reference: p. 2-3These directions included creating nodal officers, witness registers, and monitoring mechanisms
Source reference: p. 5-7The Appellant challenged the High Court's authority to issue such systemic administrative directions while exercising statutory bail jurisdiction
Source reference: p. 2Issues
Whether the High Court, while exercising its statutory power to grant or deny bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, has the jurisdiction to issue far-reaching administrative directions regarding the state's criminal justice infrastructure and departmental accountability
Source reference: p. 7 / para. 5Law Applied
Section 483 of the BNSS (formerly Section 439 Cr.P.C.), which defines the special powers of the High Court or Court of Session regarding bail
Source reference: p. 8The Court primarily interpreted Section 483 of the BNSS... It relied heavily on the precedent State of U.P. v. Anurudh (2026), which distinguishes between "Constitutional power" (inherent, sovereign powers emanating from the Constitution) and "Statutory power" (derivative powers limited by the enabling statute)
Source reference: p. 9-10The rule established is that a statutory power cannot be used to enlarge a court's scope beyond what the legislature envisaged, and judicial review under a specific statute must conform strictly to that statute’s parameters
Source reference: p. 11Reasoning
The jurisdiction under Section 483 of the BNSS is strictly limited to adjudicating whether an accused should be released pending trial or remain incarcerated
Source reference: para. 7 / p. 9The High Court erred by treating its statutory bail jurisdiction as a platform to exercise broad constitutional or supervisory powers
Source reference: p. 11In applying the Anurudh principle, the Court found that while the High Court is a Constitutional Court, when it acts under a specific statute (BNSS), its orders must remain within the "four corners" of that law
Source reference: p. 10Systemic directions regarding the administrative functioning of the police and the service of summons exceed the specific mandate of deciding a bail application, thus rendering such directions ultra vires of the statutory power conferred by Section 483
Source reference: p. 11Holding
The High Court cannot issue systemic administrative directions while exercising bail jurisdiction
the Supreme Court set aside the impugned directions for jurisdictional error... However, to avoid administrative chaos, the Court directed that the steps already taken by the State authorities (like the appointment of nodal officers) would remain unaffected and continue to function independently of the quashed court orders. The interim bail granted to the Appellant on 26th November 2025 was confirmed
Source reference: p. 11-12Original Court PDF
RambalakvsState Of U.P.
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