Article 226 cannot be used for blanket pre-arrest protection during ongoing investigations where statutory remedies remain available.

A writ petition under Article 226 cannot be used to obtain blanket interim protection from arrest or coercive action during ongoing criminal investigations, particularly where no quashing of the FIRs or ECIRs is sought. The High Court emphasised that interference at the investigative stage should remain limited, as an accused has statutory remedies such as anticipatory bail and, where appropriate, quashing proceedings. Granting a no-arrest or no-coercive-order direction in these circumstances would improperly bypass the criminal law framework and obstruct investigation. The petition was therefore held not maintainable and the request for blanket interim protection was rejected.

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Issues: Whether a writ petition under Article 226 of the Constitution of India seeking blanket interim protection from arrest and supervision of multiple ongoing criminal investigations was maintainable without seeking quashing of the FIRs or ECIRs.

Analysis: The petition sought wide interim protection in relation to multiple investigations, but the Court held that such blanket protection cannot be granted in the course of pending investigation. Relying on settled principles that High Courts should be slow to interfere at the investigative stage, the Court noted that an accused apprehending arrest has statutory remedies by way of anticipatory bail and, where appropriate, quashing proceedings. The Court further held that a writ court cannot convert Article 226 into a substitute for those remedies, particularly where no prayer for quashing of the FIRs or ECIRs was made. In such circumstances, granting a blanket no-arrest or no-coercive-order would impede investigation and would be contrary to the settled law governing criminal process.

Conclusion: The writ petition was not maintainable and the request for blanket interim protection was rejected.

Ratio Decidendi: A writ petition under Article 226 cannot be used to obtain a blanket pre-arrest protection during ongoing investigations when the petitioner has not sought quashing of the criminal proceedings and has adequate statutory remedies available under the criminal law framework.

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