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High Court of Gujarat

MANDEEPSINH GIRVANSINH GOHILversusSTATE OF GUJARAT

Disposal
56-DISPOSED AT ADMISSION STAGE

Holding

The court disposed of the anticipatory bail application, directing the investigating officer to comply with Supreme Court precedents and to give the applicant a seven‑day notice before any arrest.

Summary

Mandeepsinh Girvansinh Gohil applied for anticipatory bail, stating his willingness to cooperate with the investigation and to appear before the investigating officer on 5 March 2026. The court examined the submissions and directed the investigating officer to adhere to Supreme Court rulings in Arnesh Kumar v. State of Bihar, Satender Kumar Antil v. CBI, and Md. Asfak Alam v. State of Jharkhand regarding the procedure for arrest. It emphasized that the grounds of arrest must be communicated to the magistrate and that the magistrate should not mechanically authorize detention. The court further ordered that, if arrest becomes necessary, a seven‑day notice must be given to the applicant prior to arrest. Consequently, the anticipatory bail application was disposed of with these procedural directions.

Issues considered

  • Whether anticipatory bail should be granted to the applicant
  • Whether the investigating officer must provide a seven‑day notice before arrest in accordance with Supreme Court jurisprudence

Subjects

anticipatory bailarrest procedurenotice before arrestSupreme Court precedentCriminal Procedure CodeSection 41Gujarat High Court

Judgment

   R/CR.MA/4649/2026                              ORDER DATED: 24/02/2026




          IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

R/CRIMINAL MISC.APPLICATION (FOR ANTICIPATORY BAIL) NO. 4649
                          of 2026

==========================================================
                       MANDEEPSINH GIRVANSINH GOHIL
                                  Versus
                            STATE OF GUJARAT
==========================================================
Appearance:
MR PRITESHKUMAR A VAGHELA(10078) for the Applicant(s) No. 1
MS. MAITHILI MEHTA, APP for the Respondent(s) No. 1
==========================================================

 CORAM:HONOURABLE MR.JUSTICE UTKARSH THAKORBHAI
       DESAI

                              Date : 24/02/2026

                               ORAL ORDER


     Learned advocate Mr. A.S. Timbaliya on behalf of learned

advocate Mr. P.A. Vaghela for the applicant, under instructions,

states that the applicant is ready and willing to co-operate with

the investigation, and will appear before the investigating o!cer

on 05.03.2026.

     Having considered the submissions and the documents

produced on record, the Investigating O!cer is directed to

scrupulously follow the proposition of law as settled by the

Hon'ble Supreme Court in the case of Arnesh Kumar Vs. State of

Bihar, reported in (2014) 8 SCC 273, in case of Satender Kumar

Antil Vs. Central Bureau of Investigation & Anr., reported in

(2022) 10 SCC 51 and in case of Md. Asfak Alam Vs. State of

                                  Page 1 of 2
     R/CR.MA/4649/2026                                                    ORDER DATED: 24/02/2026




Jharkhand & Anr., reported in 2023 SCC OnLine SC 892 and

also inform about the grounds of arrest, if needed, to learned

Magistrate and even the learned Magistrate before mechanically

authorizing the detention of the applicant shall follow the dictum

of the Hon'ble Supreme Court in the aforesaid decisions.

        In case, the Investigating O!cer needs to arrest the

applicant, notice of 7 days shall be given to the applicant prior to

such arrest.

        In view of the above, the present application stands

disposed of.


                                                      (UTKARSH THAKORBHAI DESAI, J)
ANIRUDH OJHA




  Original copy of this order has been signed by the Hon'ble Judge.
  Digitally signed by: ANIRUDH OJHA(HC02370), ENGLISH STENO GRADE-II\, at High Court of Gujarat on 24/02/2026 16:31:34




                                               Page 2 of 2


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