Article 226 limits interim bail directions when substantive writ relief is refused, and mandatory bail orders were set aside.

A writ court cannot grant ancillary relief under Article 226 after declining the main prayer to quash an FIR, and extraordinary bail-related directions under that provision are permissible only in rare and extreme cases supported by reasons. Here, the High Court refused to quash the FIR but still directed the Magistrate to enlarge the respondents on bail on filing of an application. That mandatory direction was held inconsistent with the governing law and was set aside. The matter was remanded for fresh consideration of bail in accordance with law after hearing both parties.

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Issues: Whether the High Court, after declining to quash the FIR in a writ petition under Article 226, could direct the Magistrate to enlarge the respondents on bail on filing of a bail application.

Analysis: The direction issued by the High Court was examined against the settled principle that relief under Article 226 cannot be granted as an interim or ancillary measure when the main relief itself is declined. The Court also considered the limited and sparing nature of extraordinary bail-related directions under Article 226, which are permissible only in rare and extreme circumstances, and only when supported by reasons. Since the High Court had refused the substantive writ relief yet still issued a mandatory direction affecting the bail decision of the Magistrate, the direction was found to be inconsistent with the governing law.

Conclusion: The direction to the Magistrate to enlarge the respondents on bail was set aside as contrary to law, and the matter was remanded for fresh consideration of bail in accordance with law after hearing the parties.

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