Supreme Court: Default Bail Requires No Deposit.

The Supreme Court held that imposing deposit conditions for default bail/statutory bail under Section 167(2), Cr.P.C. would defeat the purpose of the provision, emphasizing that the only requirement for default bail is the expiry of the statutory period and the accused's willingness to furnish bail. The Court ruled that conditions set during regular bail applications should not influence conditions for default bail, emphasizing that default bail is meant to safeguard personal liberty when investigation deadlines are not met. The Court reiterated that default bail is available once the statutory period lapses without additional conditions like depositing specific amounts. The Court quashed the deposit condition for bail and modified the reporting condition, focusing on personal liberty and statutory bail provisions under Section 167 Cr.P.C.

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Issues:
1. Imposition of conditions for default bail/statutory bail under Section 167(2), Cr.P.C.
2. Validity of conditions imposed by the High Court while releasing the appellant on bail.
3. Interpretation of the scheme of Section 167 Cr.P.C.
4. Justifiability of directing the appellant to deposit a specific amount as a condition for bail.
5. Legality of directing the appellant to report to the police station daily for interrogation.

Analysis:

Issue 1: Imposition of conditions for default bail/statutory bail under Section 167(2), Cr.P.C.
The appellant challenged the conditions imposed for default bail/statutory bail under Section 167(2), Cr.P.C. The High Court had directed the appellant to deposit a specific amount before the Judicial Magistrate. The appellant argued that such conditions were contrary to the scheme of Section 167 and infringed upon personal liberty. The Supreme Court held that imposing deposit conditions for default bail/statutory bail would defeat the purpose of the provision, which entitles the accused to bail if investigation is not completed within the stipulated time. The Court emphasized that the only requirement for default bail is the expiry of the statutory period and the accused's willingness to furnish bail.

Issue 2: Validity of conditions imposed by the High Court while releasing the appellant on bail
The High Court had imposed conditions based on the appellant's previous bail application and an affidavit filed by the appellant's wife. The Supreme Court ruled that conditions set during regular bail applications should not influence conditions for default bail/statutory bail under Section 167(2), Cr.P.C. The Court emphasized that the purpose of default bail is to safeguard personal liberty when investigation deadlines are not met, and any additional conditions beyond statutory requirements are unjustified.

Issue 3: Interpretation of the scheme of Section 167 Cr.P.C.
The Court reiterated that Section 167 Cr.P.C. upholds personal liberty by providing default bail when investigation deadlines are breached. The Court emphasized that the accused is entitled to default bail once the statutory period lapses and no chargesheet is filed, without the need for additional conditions like depositing specific amounts.

Issue 4: Justifiability of directing the appellant to deposit a specific amount as a condition for bail
The Court found that directing the appellant to deposit a specific amount while granting default bail was unsustainable and against the principles of Section 167. The Court emphasized that the focus should be on statutory requirements, not financial obligations, for default bail eligibility.

Issue 5: Legality of directing the appellant to report to the police station daily for interrogation
The Court deemed the condition directing the appellant to report daily for interrogation too harsh and modified it. Instead, the Court directed the appellant to cooperate with the investigating officer and appear for interrogation when required, with non-cooperation potentially leading to bail cancellation.

In conclusion, the Supreme Court allowed the appeals, quashed the deposit condition for bail, and modified the reporting condition, emphasizing the primacy of personal liberty and statutory bail provisions under Section 167 Cr.P.C.

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