T K Kosal Ram Vs State Rep by The Inspector of Police — Anticipatory Bail | Madras HC (2026)

T K Kosal Ram Vs State Rep by The Inspector of Police — Anticipatory Bail | Madras HC (2026)

What the court decided

AI extract

Outcome

The criminal original petition was not decided by granting or refusing bail; it was disposed of with directions: respondent Police to follow the Satender Kumar Antil procedure, enquiry to be completed within two weeks (register F.I.R or close the petition enquiry if a prima facie case is/not made out), parties to cooperate, and no coercive steps against the petitioner till completion of the enquiry.

Issue for consideration

Whether anticipatory bail should be granted to the petitioner, who apprehends arrest for alleged offences under Sections 316 and 318 of BNSS in Crime No. Not known of 2026 on the file of the respondent police.

Court's answer

The respondent Police were directed to follow the procedure laid down by the Hon'ble Supreme Court in Satender Kumar Antil v. Central Bureau Of Investigation, reported in (2026 INSC 115) and 2025 SCC OnLine SC 1578, with the Investigating Officer to conduct the enquiry by strictly following the procedures therein.

Ratio / Principle

If a prima facie case is made out against the petitioner during the enquiry conducted per the Satender Kumar Antil procedure, the Investigating Officer is to register the F.I.R; otherwise the petition enquiry is to be closed.

Key takeaways

The F.I.R is to be registered or the petition enquiry closed within a period of two weeks from the date of the order, and the parties are directed to cooperate with the enquiry.ratio¶20
The respondent police shall not take any coercive steps to secure the accused till the completion of the enquiry arising from the complaint lodged by the defacto complainant.ratio¶20

Detailed headnote1 paragraphs

Anticipatory bail petition filed under Section 482 of BNSS by T K Kosal Ram apprehending arrest in connection with Crime No. Not known of 2026 (Ambathur Estate Police Station) for alleged offences under Sections 316 and 318 of BNSS. The Government Advocate informed the Court that a petition enquiry was pending against the petitioner. Instead of granting or refusing bail, the Madras High Court (C.Kumarappan, J.; order dated 03-06-2026) disposed of the petition by directing the respondent Police to follow the procedure laid down by the Supreme Court in Satender Kumar Antil v. Central Bureau Of Investigation, (2026 INSC 115) / 2025 SCC OnLine SC 1578: the Investigating Officer to conduct the enquiry strictly per those procedures and, within two weeks, register the F.I.R or close the petition enquiry depending on whether a prima facie case emerges; parties to cooperate; and no coercive steps to be taken against the accused till completion of the enquiry on the defacto complainant's complaint.

CRL OP No. 13339 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 03-06-2026

CORAM

THE HON'BLE MR.JUSTICE C.KUMARAPPAN

CRL OP No. 13339 of 2026

T K Kosal Ram S/o. Mr.J.N.Karunakaran, No.18, Poondi Madha Street, Lakshmi Amman Nagar, Kodungaiyur, Chennai-600118

..Petitioner(s)

Vs

State Rep by, The Inspector of Police T2, Ambathur Estate Police Station, Chennai 600058 Crime No. Not Known of 2026

..Respondent(s)

PRAYER : Criminal Original Petition filed under Section 482 of BNSS, to enlarge the Petitioner on bail in apprehend of his arrest in connection with Crime No. Not known of 2026 on the file of respondent Police and thus render justice.

For Petitioner(s): M/S. M.K.Bhoopathy Rajan For Respondent(s): Mr.N.Palanivel, Government Advocate (Crl.Side)

__________ Page1 of 4

https://www.mhc.tn.gov.in/judis

CRL OP No. 13339 of 2026

ORDER

The petitioner apprehends arrest for the alleged offence under Sections 316 and 318 of BNSS, in Crime No. Not known of 2026, seeks anticipatory bail.

When the matter is taken up for hearing today, the learned Government Advocate (Crl.Side) appearing for the respondent submits that petition enquiry is pending against the petitioner.

In such circumstances, this Court is of the firm view that the respondent Police may be directed to follow the procedure as laid down by the Hon’ble Supreme Court in Satender Kumar Antil v. Central Bureau Of Investigation reported in (2026 INSC 115) and 2025 SCC OnLine SC 1578 and the Investigating Officer has to conduct the enquiry by strictly following the procedures therein and if any prima facie case is made out against the petitioner, register the F.I.R or close the petition enquiry within a period of two weeks from today. The parties are directed to cooperate with the enquiry. It is needless to say that the respondent police shall not take any coercive steps to secure the accused till the completion of enquiry, on the complaint lodged by the defacto complainant.

__________ Page2 of 4

https://www.mhc.tn.gov.in/judis

CRL OP No. 13339 of 2026

With the above directions, this criminal original petition is disposed of.

03-06-2026

Vv

To

The Inspector of Police T2, Ambathur Estate Police Station, Chennai 600058

The Public Prosecutor, High Court of Madras.

__________ Page3 of 4

https://www.mhc.tn.gov.in/judis

CRL OP No. 13339 of 2026

C.KUMARAPPAN, J.

VV

CRL OP No. 13339 of 2026

03-06-2026

__________ Page4 of 4

https://www.mhc.tn.gov.in/judis

CRL OP No. 13339 of 2026

__________ Page5 of 4

https://www.mhc.tn.gov.in/judis