Non-bailable warrants justified where repeated non-appearance and ignored court directions made lesser coercive measures ineffective.

Repeated non-appearance despite successive directions and express warnings justified the resort to non-bailable warrants, as lesser coercive measures had failed to secure the petitioner's physical attendance. The Court noted that the petitioner had repeatedly sought exemption from personal appearance, had not complied with directions to appear before the Trial Court, and had also failed to appear before the investigating agency during investigation. Applying the principle that non-bailable warrants may be issued when summons or milder process are unlikely to ensure attendance, the Court found no illegality or infirmity in the impugned order and declined to quash the warrants.

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Issues: Whether the non-bailable warrants issued against the petitioner were liable to be quashed.

Analysis: The petitioner had repeatedly sought exemption from personal appearance and had not complied with successive directions to appear physically before the Trial Court. The Trial Court had earlier taken a lenient view on several occasions, allowed only limited virtual appearance, and expressly warned that failure to appear physically would lead to coercive process. The petitioner also had not appeared before the investigating agency during investigation, and the Trial Court had considered his overall conduct, including earlier proceedings in the connected matter, before issuing warrants. The governing principle is that non-bailable warrants are to be used when summons or lesser coercive measures are unlikely to secure attendance, while balancing personal liberty with the need to secure the administration of justice.

Conclusion: The non-bailable warrants were not liable to be quashed and the challenge failed.

Final Conclusion: Repeated non-appearance despite clear judicial directions justified the coercive process, and the impugned order did not suffer from illegality or infirmity.

Ratio Decidendi: Where an accused repeatedly avoids physical appearance despite prior opportunities and explicit warnings, the Court may lawfully resort to non-bailable warrants when lesser measures have proved ineffective.

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