Police custody under Section 167 cannot be extended after the initial 15-day period, even for later-discovered offences.

Section 167 of the Code of Criminal Procedure bars police custody beyond the initial 15 days after arrest. The SC held that once that period has expired, the remand cannot be reopened by directing further police custody, even if later-discovered offences arise from the same transaction. An order authorising additional police remand after expiry of the first 15-day window was therefore inconsistent with the statutory limitation and was set aside.

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Issues: Whether police remand can be granted after the expiry of the first 15 days of custody under Section 167 of the Code of Criminal Procedure, 1973.

Analysis: The statutory scheme of Section 167 bars detention in police custody beyond the first 15 days after arrest. The Court held that the expired remand period could not be extended by directing further police custody, and that the High Court's order authorising seven more days of police remand was inconsistent with the statutory limitation. Reliance was placed on the settled scope of Section 167 to hold that later-discovered offences in the same transaction do not reopen the police-custody window once the first 15 days have elapsed.

Conclusion: The order granting further police remand after expiry of the initial 15-day period was unsustainable and was set aside in favour of the appellant.

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