Territorial jurisdiction for anticipatory bail depends on reasonable apprehension of arrest, not only place of offence.

Territorial jurisdiction to entertain an anticipatory bail application under Section 438 of the Code of Criminal Procedure is not limited to the place where the alleged offence occurred. The relevant test is whether the applicant has a reasonable apprehension of arrest within the territorial jurisdiction of the court approached. Applying that principle and the cited precedent on concurrent jurisdiction, the court held that the place where arrest was apprehended was sufficient to confer jurisdiction to hear the application.

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Issues: Whether the court had territorial jurisdiction to entertain the application for anticipatory bail under Section 438 of the Code of Criminal Procedure, 1973.

Analysis: Jurisdiction to consider anticipatory bail is not confined to the place where the offence is alleged to have been committed. The relevant consideration is whether the applicant has a reasonable apprehension of arrest within the territorial jurisdiction of the court approached. On that basis, and applying the cited precedent on concurrent jurisdiction, the court found that the place where arrest was apprehended conferred jurisdiction to entertain the application.

Conclusion: The court held that it had territorial jurisdiction to entertain the anticipatory bail application.

Ratio Decidendi: A court within whose territorial jurisdiction the applicant reasonably apprehends arrest has jurisdiction to entertain an application for anticipatory bail under Section 438 of the Code of Criminal Procedure, 1973.

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