Supreme Court Says High Courts Cannot Grant ‘No Arrest’ Protection While Refusing To Quash FIR

The Supreme Court has set aside an order of the Allahabad High Court which, while refusing to quash an FIR, granted protection from arrest and directed completion of the investigation within a fixed timeline.

The case relates to an FIR registered in Agra in May 2024 after an STF probe alleged fraudulent procurement of arms licences using forged identity documents.

The Supreme Court held that directing “no arrest” or “no coercive steps” directions in such circumstances amounts to anticipatory bail without satisfying the requirements of Section 438 CrPC.

It further ruled that courts can fix investigation timelines only in exceptional cases where undue delay is clearly demonstrated, and not as a routine measure.

[State of U.P. v. Mohd Arshad Khan & Anr.]