Supreme Court Upholds Fundamental Rights, Quashes Illegal Arrest in Landmark Ruling

 

Supreme Court Upholds Fundamental Rights, Quashes Illegal Arrest in Landmark Ruling
By Abhishek Jat, Advocate

In a landmark judgment, the Supreme Court of India delivered a powerful ruling in the case of Vihaan Kumar v. State of Haryana, emphasizing the critical importance of adhering to constitutional safeguards during arrests and custodial procedures. The appellant, Vihaan Kumar, was arrested in connection with a financial fraud case under various sections of the Indian Penal Code (IPC), including Sections 409, 420, 467, 468, 471, and 120-B. The arrest, which took place on June 10, 2024, was challenged on the grounds that the appellant was not informed of the reasons for his arrest, a clear violation of his fundamental right under Article 22(1) of the Constitution. Article 22(1) mandates that every arrested person must be informed of the grounds of arrest “as soon as may be,” ensuring transparency and fairness in the arrest process. The appellant contended that this constitutional requirement was not met, rendering his arrest illegal.

The Supreme Court, in its detailed judgment, held that the failure to inform the appellant of the grounds of arrest was a blatant violation of Article 22(1). The Court reiterated that this provision is not a mere procedural formality but a fundamental right designed to protect individuals from arbitrary detention. The Court rejected the state’s argument that the grounds of arrest were communicated to the appellant’s wife, emphasizing that the constitutional mandate requires the information to be conveyed directly to the arrested person. Communication to a third party, even a close family member, does not satisfy the requirement under Article 22(1). The Court also noted that the burden of proving compliance with this constitutional mandate lies squarely on the investigating agency, and in this case, the state failed to provide any evidence that the appellant was informed of the grounds of his arrest.

Furthermore, the Court addressed the issue of the appellant’s treatment during custody, particularly his hospitalization at PGIMS, Rohtak, where he was handcuffed and chained to a hospital bed. The Court strongly condemned this inhumane treatment, stating that it violated the appellant’s right to dignity under Article 21 of the Constitution. The right to live with dignity is an integral part of the right to life and personal liberty, and the Court emphasized that such degrading treatment of an accused person, regardless of the charges against them, is unacceptable. The Court directed the State of Haryana to issue guidelines to prevent such practices in the future, ensuring that the constitutional rights of individuals are respected even during custodial procedures.

The Court also clarified that the illegality of the arrest vitiates any subsequent custody or remand orders. Even though a chargesheet had been filed in the case, the Court held that this did not validate the initial arrest, which was unconstitutional due to the violation of Article 22(1). The Court emphasized that the filing of a chargesheet or the issuance of remand orders cannot cure the illegality of an arrest that violates fundamental rights. This ruling reinforces the principle that constitutional safeguards must be strictly adhered to at every stage of criminal proceedings, and any deviation from these safeguards renders the entire process unconstitutional.

In addition to quashing the arrest, the Court ordered the immediate release of the appellant, while clarifying that its decision would not affect the merits of the chargesheet or the pending trial. The appellant was directed to cooperate with the trial court and attend proceedings regularly. The Court also mandated the State of Haryana to issue guidelines to ensure that the constitutional safeguards under Article 22 are strictly followed in all future cases. This includes preventing the practice of handcuffing and chaining accused persons during hospitalization or other custodial procedures.

The judgment in Vihaan Kumar v. State of Haryana is a significant step in safeguarding individual liberties and ensuring that law enforcement agencies adhere to constitutional mandates. By quashing the illegal arrest and condemning the inhumane treatment of the appellant, the Supreme Court has reaffirmed its commitment to protecting fundamental rights. The ruling serves as a reminder that the right to liberty and dignity cannot be compromised, even in cases involving serious allegations. It also underscores the judiciary’s role as the guardian of the Constitution, ensuring that the rights of individuals are protected against arbitrary state action. This judgment will undoubtedly serve as a precedent for future cases, reinforcing the importance of due process and transparency in criminal proceedings.

Case Title: Vihaan Kumar v. State of Haryana & Anr.
Citation: 2025 INSC 162