Communication of grounds of arrest in writing found sufficient where arrest memo itself stated the factual basis, defeating bail.

Article 22(1) requires that the grounds of arrest be effectively communicated, and Section 50 CrPC supports that safeguard by requiring notice of the basis of arrest. On the facts, the arrest memo supplied to the applicant recorded the factual basis of arrest, including demand and acceptance of bribe, and was treated as written communication of the grounds. The Court held that a separate sheet was not legally necessary where the arrest memo itself conveyed those grounds. Sufficient compliance with Article 22(1) was therefore found, no violation of fundamental rights was established, and the bail plea was rejected.

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Issues: Whether the applicant was entitled to bail on the ground that the grounds of arrest were not communicated to him in writing as required by Article 22(1) of the Constitution of India.

Analysis: The bail was sought only on the plea that the arrest was vitiated for non-communication of the grounds of arrest in writing. The Court examined the constitutional safeguard under Article 22(1), the statutory obligation under Section 50 of the Code of Criminal Procedure, 1973, and the later Supreme Court decisions explaining that the grounds of arrest are the basic facts constituting the offence and must be effectively communicated. On the facts, the arrest memo supplied to the applicant recorded the factual basis of arrest, namely demand and acceptance of bribe, and the Court treated that memo as conveying the grounds of arrest in writing. The Court held that separate recording on a distinct sheet was not legally required where the document supplied at arrest itself contained the grounds.

Conclusion: There was sufficient compliance with Article 22(1) of the Constitution of India and no violation of the applicant's fundamental rights was established; the bail plea was therefore rejected.

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