Criminal Law

Arrest Rights: Written Grounds of Arrest Mandatory in All Cases

Supreme Court establishes that grounds of arrest must be provided in writing in all criminal cases, with exceptions only for flagrante delicto offences where written grounds must be supplied at least 2 hours before remand hearing

Case Reference: Mihir Rajesh Shah vs State of Maharashtra (Criminal Appeal No.2195 of 2025) Decided by: Supreme Court of India Date: November 06, 2025

❓ Question

IS IT MANDATORY TO PROVIDE GROUNDS OF ARREST IN WRITING IN ALL CRIMINAL CASES, OR ARE THERE EXCEPTIONS?

✅ Answer

YES, WRITTEN GROUNDS OF ARREST ARE MANDATORY IN ALL CASES. The Supreme Court has established that grounds of arrest must be provided in writing to the arrestee in all criminal cases. The only exception is for flagrante delicto offences where immediate written communication is impractical, but even in such cases, written grounds must be supplied within a reasonable time and at least 2 hours before the remand hearing.

⚖️ Understanding the Legal Principles

🔹 Constitutional Mandate

  • Article 22(1) of Constitution guarantees right to know grounds of arrest
  • This is a fundamental right, not a mere procedural formality
  • Applies to all offences under all statutes
  • Mode of communication must be meaningful and effective

🔹 Statutory Provisions

  • Section 47 of BNSS 2023 (Section 50 CrPC 1973)
  • Section 48 of BNSS 2023 (Section 50A CrPC 1973)
  • Grounds must be communicated "forthwith"
  • Information must also be given to relatives/friends

🔹 Written Communication Requirement

  • Written grounds mandatory to avoid factual disputes
  • Must be in language the arrestee understands
  • Prevents "word against word" situations
  • Enables effective legal consultation

🔹 Limited Exceptions

  • Flagrante delicto offences (caught red-handed)
  • Where immediate written communication impractical
  • Oral communication permitted initially
  • Written grounds must follow within reasonable time

📜 Key Legal Timeline

🧭 Your Action Plan: Understanding Arrest Rights

📝 If You or Someone You Know is Arrested

✅ Step 1: Demand Written Grounds

  • Politely ask for written grounds of arrest
  • If refused, note the refusal and officers' details
  • Request grounds in language you understand
  • Ensure grounds are specific, not generic

✅ Step 2: Inform Family/Lawyer

  • Exercise right under Section 48 BNSS 2023
  • Provide contact details of relative/friend
  • Ensure police inform them of arrest and location
  • Contact lawyer immediately if possible

⚖️ Key Legal Rights During Arrest

Legal Right Constitutional/Statutory Basis Practical Application
Written Grounds of Arrest Article 22(1), Section 47 BNSS 2023 Must be provided in writing in understandable language
Information to Relative/Friend Section 48 BNSS 2023 Police must inform nominated person about arrest
Legal Consultation Article 22(1) Constitution Right to consult legal practitioner of choice
Production Before Magistrate Article 22(2), Section 58 BNSS 2023 Within 24 hours of arrest excluding journey time

⚖️ When Arrest May Be Illegal

❌ Grounds for Challenging Arrest

  • No written grounds provided
  • Grounds not provided in understandable language
  • Family not informed as required
  • Not produced before magistrate within 24 hours
  • Grounds provided after remand hearing

📘 Key Legal Terms Explained

Article 22(1) Constitution

Fundamental right guaranteeing that no arrested person shall be detained without being informed of grounds of arrest and right to consult legal practitioner.

Section 47 BNSS 2023

Statutory provision requiring police officer to forthwith communicate full particulars of offence and grounds of arrest to arrested person.

Flagrante Delicto

Latin term meaning "in the very act of committing a crime" - situations where person is caught red-handed committing offence.

Remand Proceedings

Judicial process where arrested person is produced before magistrate who decides whether to grant police custody or judicial custody.

Forthwith Communication

Legal requirement to communicate grounds of arrest immediately or as soon as possible after arrest.

🚨 What Police Must Do During Arrest

✅ Mandatory Police Duties

  • Provide written grounds of arrest
  • Ensure grounds are in understandable language
  • Inform relative/friend about arrest
  • Make entry in police station records
  • Produce before magistrate within 24 hours

✅ Exceptional Circumstances Procedure

  • Oral communication permitted initially
  • Written grounds must follow within reasonable time
  • At least 2 hours before remand hearing
  • Note explaining delay must be included
  • Magistrate must verify compliance

💡 Core Takeaway from the Supreme Court

"We hold that to achieve the intended objective of the constitutional mandate of Article 22(1) of the Constitution of India, the grounds of arrest must be informed to the arrested person in each and every case without exception and the mode of the communication of such grounds must be in writing in the language he understands."

This landmark judgment establishes that written communication of grounds of arrest is not just a procedural formality but a constitutional safeguard essential for protecting personal liberty. The Supreme Court emphasized that this requirement applies to all offences under all statutes, making no distinction between ordinary crimes and special statute offences.

The Court recognized only one limited exception - for flagrante delicto offences where immediate written communication may be impractical. However, even in such cases, written grounds must be supplied within a reasonable time and at least 2 hours before the remand hearing to ensure the arrested person has adequate time to consult legal counsel and prepare for the remand proceedings.

This judgment harmonizes the previous conflicting decisions in Pankaj Bansal, Prabir Purkayastha, and Vihaan Kumar cases, providing clear guidelines for law enforcement agencies while strengthening the fundamental rights of arrested persons.

📞 When to Seek Professional Help

👨‍⚖️ Criminal Lawyer Essential For

  • Challenging illegal arrest procedures
  • Filing habeas corpus petitions
  • Representation in remand proceedings
  • Appeals against illegal detention
  • Complex constitutional law arguments

📝 You Can Handle With Support

  • Understanding basic arrest rights
  • Knowing when to demand written grounds
  • Exercising right to inform family
  • Basic understanding of time limits
  • Initial assessment of arrest legality

⚠️ DISCLAIMER

This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.

🌿 LegalEcoSys Mission

Making Supreme Court judgments accessible and actionable for every Indian citizen navigating legal challenges.

This roadmap decodes a landmark criminal procedure judgment to help citizens understand their fundamental rights during arrest. It clarifies that written communication of arrest grounds is not just procedural but a constitutional safeguard essential for protecting personal liberty against arbitrary state action.