Default bail requires a timely police report under Section 173(2); later documents do not invalidate it.

The SC held that for default bail under Section 167(2) CrPC, a police report filed within the statutory period is sufficient if it contains the particulars required by Section 173(2). The later filing or absence of supporting documents does not render the report incomplete, because Section 173(5) is directory and additional material may be produced later with the court's permission. Since the report was filed on time and cognizance was taken the same day, the right to default bail did not arise or revive. The appellant was therefore not entitled to default bail.

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Issues: Whether the appellant was entitled to default bail under Section 167(2) of the Code of Criminal Procedure, 1973 on the ground that the police report was incomplete because supporting documents were filed later, and whether the filing of the police report on the 90th day defeated the claim for default bail.

Analysis: The police report was filed within the prescribed period and contained the particulars required by Section 173(2) of the Code of Criminal Procedure, 1973. The expression "police report" in Section 2(r) refers to a report forwarded under Section 173(2), and the report here satisfied that requirement. The absence or later filing of some documents did not render the report incomplete for the purpose of default bail, because Section 173(5) was treated as directory and additional documents could be produced subsequently with the court's permission. Cognizance was taken on the same day, and the order taking cognizance remained unchallenged.

Conclusion: The appellant was not entitled to default bail, because the police report had been validly filed within time and the later filing of documents did not revive the right under Section 167(2).

Ratio Decidendi: For the purpose of default bail, timely filing of a police report containing the particulars required by Section 173(2) is sufficient; Section 173(5) is directory and the subsequent filing of additional documents does not invalidate the report or create an entitlement to bail under Section 167(2).

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