Udhayavarma Vs The State rep by, The Inspector of Police — Anticipatory Bail | Madras HC (2026)

Udhayavarma Vs The State rep by, The Inspector of Police — Anticipatory Bail | Madras HC (2026)

What the court decided

AI extract

Outcome

Criminal Original Petition disposed of with directions: the respondent Police to follow the Satender Kumar Antil procedure in the pending petition enquiry, to register an F.I.R or close the petition enquiry within two weeks if a prima facie case is made out, both parties to cooperate with the enquiry, and no coercive steps to be taken against the petitioner till completion of the enquiry on the de facto complainant's complaint.

Issue for consideration

Whether the petitioner, who apprehends arrest for the alleged offence under Sections 420 & 316 of BNS in Crime No. 137 of 2025, should be enlarged on bail in the event of arrest (anticipatory bail under Section 482 of BNSS).

Court's answer

This Court held that the respondent Police may be directed to follow the ratio laid down by the Hon'ble Supreme Court in Satender Kumar Antil v. Central Bureau of Investigation, reported at (2026 INSC 115) and 2025 SCC OnLine SC 1578.

Ratio / Principle

The Investigating Officer must conduct the pending petition enquiry by strictly following the procedures laid down in Satender Kumar Antil, 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 the date of the order.

Key takeaways

The parties are directed to cooperate with the enquiry.ratio¶21
The respondent police shall not take any coercive steps to secure the accused till the completion of the enquiry, on the complaint lodged by the de facto complainant.ratio¶21

Detailed headnote1 paragraphs

Anticipatory bail — Criminal Original Petition under S. 482 BNSS by petitioner apprehending arrest under Ss. 420 & 316, BNS, in Crime No. 137 of 2025, Manavalanagar Police Station, Thiruvallur District — petition enquiry pending — Court directs respondent Police to follow the ratio in Satender Kumar Antil v. Central Bureau of Investigation ((2026 INSC 115); 2025 SCC OnLine SC 1578) — Investigating Officer to conduct enquiry strictly per those procedures and, if a prima facie case is made out, register the F.I.R or close the petition enquiry within two weeks — parties to cooperate — no coercive steps till completion of enquiry on the de facto complainant's complaint — petition disposed of (C.Kumarappan, J., 15-07-2026).

CRL OP No. 18417 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 15-07-2026

CORAM

THE HON'BLE MR.JUSTICE C.KUMARAPPAN

CRL OP No. 18417 of 2026

Udhayavarma S/o.Viswanathan, No.001, Pattanur, Jakkampatti Post, Dharmapuri District.

..Petitioner(s)

Vs

The State rep by, The Inspector of Police, Manavalanagar Police Station, Thiruvallur District. Crime No.Not Known of 2026

..Respondent(s)

Criminal Original Petition filed under Section 482 of BNSS, praying to enlarge the petitioner on bail in the event of arrest in Crime No.Not Nown of 2026 on the file of the Respondent and thus render Justice.

For Petitioner(s): M/s.C.Deepak Kumar For Respondent(s): Mr.N.Palanivel, Govt.Advocate (Crl.Side) ********

ORDER

The petitioner, who apprehends arrest for the alleged offence under

Sections 420 & 316 of BNS in Crime No. 137 of 2025, seeks anticipatory bail.

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CRL OP No. 18417 of 2026

2. Today, when the matter was taken up for hearing, the learned Government Advocate (Criminal Side) appearing for the respondent Police submitted that the petition enquiry is pending against the petitioner.

3. In such circumstances, this Court is of the firm view that the respondent Police may be directed to follow the ratio 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 de facto complainant.

4. With the above directions, this Criminal Original Petition is disposed of.

15-07-2026

KMI To

1.The Inspector of Police, Manavalanagar Police Station, Thiruvallur District. 2.The Public Prosecutor, Madras High Court.

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CRL OP No. 18417 of 2026

C.KUMARAPPAN, J.

KMI

CRL OP No. 18417 of 2026

15-07-2026

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