Reasonable apprehension of arrest is essential for pre-arrest bail; a CGST summons alone does not establish it.

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....Pre-arrest bail under the BNSS requires a reasonable apprehension of arrest. A summons under section 70 of the CGST Act requiring a person to provide a statement and documents does not, by itself, establish that apprehension where no notice under section 35(3) of the BNSS has been issued. An application for anticipatory bail in those circumstances is not maintainable. The applicant may seek appropriate protection if a notice under section 35(3) is subsequently issued.....