Blanket protection from arrest cannot follow refusal to quash an FIR; anticipatory bail safeguards must still be satisfied.

A High Court, after refusing to quash an FIR under Section 482 CrPC, cannot impose a blanket restraint on arrest during investigation, because that relief effectively grants anticipatory bail without the statutory safeguards for such protection. The accused must seek liberty through the remedies provided in the Code, including anticipatory bail or regular bail, and investigation should not be obstructed by an unreasoned protective direction. The blanket prohibition on arrest was therefore unlawful and was set aside, while the refusal to quash the FIR remained undisturbed.

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Issues: Whether a High Court, while declining to quash an FIR under Section 482 of the Code of Criminal Procedure, 1973, can nevertheless pass a blanket order restraining the investigating agency from arresting the accused during investigation.

Analysis: The petition for quashing was rejected on merits, but the High Court simultaneously directed that one accused should not be arrested and that the investigation be completed without arrest. Such a direction, in substance, operates as an order akin to anticipatory bail without satisfying the statutory requirements for that relief. Where the High Court finds no ground to quash the FIR, the proceeding ordinarily ends at that point, and a further blanket restraint on arrest has no legal basis. An accused who seeks protection of liberty must pursue the remedies available under the Code, including anticipatory bail or regular bail, and the investigation cannot be impeded by an unreasoned protective order.

Conclusion: The blanket restraint on arrest was unlawful and was set aside. The refusal to quash the FIR was left undisturbed.

Ratio Decidendi: A High Court cannot, while declining to quash an FIR under Section 482 of the Code of Criminal Procedure, 1973, grant a blanket prohibition against arrest during investigation, because such relief amounts to anticipatory bail without compliance with the statutory safeguards.

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