DR.

RAM MANOHAR LOHIA

NATIONAL LAW UNIVERISTY

Types of Bail

under the Indian Criminal Justice system

Submitted to Submitted by

Dr. Prem Kumar Gautam Param Chaudhary

Associate Professor Enrolment No. – 210101099

Code of Criminal Procedure B.A. L.L.B (Hons.)

Dr. Ram Manohar Lohia National Law University 5th Semester, Section ‘B’

1
 DECLARATION

I hereby declare that my project work titled “Types of Bail under the Indian Justice System”

submitted to the Law department, Dr. Ram Manohar Lohia National Law University, Lucknow

is a record of an original work done by me under the guidance of Dr. Prem Kumar Gautam and

this project work is submitted in the partial fulfilment of the requirements for the award of the

degree of B.A. LLB.(hons). This project work has not been submitted to any other University

or Institute for the award of any degree or diploma.

2
 ACKNOWLEDGEMENT

I would like to express profound gratitude to Dr. Prem Kumar Guatam, Prof. (Law), who

gave me the opportunity to work on this project and allowed me to develop the skills and

acquire the necessary knowledge to complete this project. I would also like to express humble

gratitude for the exemplary guidance, monitoring and constant encouragement throughout the

course of this project.

I would also like to thank the faculty of Dr. Madhu Limaye Library who extended their

assistance to me by helping me consult relevant legal research material which was essential to

the completion of this project.

Lastly, I would like to thank my family for their constant encouragement without which this

project would not have been possible to complete.

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 INDEX

S. No. HEADING PAGE NO.

1 BAIL 5-7

2 ORIGIN 8 - 11

3 TYPES OF BAIL 12

4 REGULAR BAIL 12 - 13

5 BAIL UNDER NON-BAILABLE OFFENCES 13 - 15

6 ANTICIPATORY BAIL 16 - 18

7 INTERIM BAIL 19 - 20

8 STATUTORY BAIL 21 - 22

9 CONCLUSION 23 - 24

10 BIBLIOGRAPHY 25

4
 BAIL

Bail, as a fundamental component of the criminal justice system, plays a pivotal role in

balancing the rights of the accused with the interests of society at large. It is a legal

mechanism that allows individuals accused of a crime to be released from custody pending

their trial, ensuring that they remain a part of society while the legal process unfolds. Under

the Criminal Procedure Code, various types of bail are recognized, each tailored to specific

circumstances and considerations.

The concept of bail is deeply rooted in the principles of justice, equity, and the presumption

of innocence until proven guilty. It represents a crucial aspect of due process, designed to

safeguard the rights and liberties of individuals accused of crimes, while also serving the

broader objectives of maintaining public safety and ensuring the appearance of the accused at

trial. This delicate balance between individual rights and societal interests is precisely what

makes the study of bail under the Criminal Procedure Code both intricate and essential.

This project delves into the multifaceted realm of bail in the context of the Criminal

Procedure Code, seeking to provide a comprehensive understanding of its various types,

intricacies, and significance within the criminal justice framework.

To begin this exploration, it is vital to recognize that bail serves as a mechanism to mitigate

the adverse effects of pretrial detention. Incarceration before trial can have profound

consequences for the accused, impacting their employment, family life, and overall well-

being. Moreover, it can lead to overcrowded prisons, straining already burdened criminal

justice systems. Therefore, the concept of bail is rooted in the belief that those accused of

5
crimes should be granted the opportunity to remain free unless there are compelling reasons

to the contrary.

Under the Criminal Procedure Code, there are several types of bail arrangements that reflect

the diverse circumstances of each case. These types include regular bail, anticipatory bail,

interim bail, and more. Regular bail is perhaps the most common form, granted to individuals

who are already in custody and seek release during the pendency of their trial. Anticipatory

bail, on the other hand, is sought in anticipation of arrest, primarily to protect individuals

from unwarranted detention. Interim bail is a temporary release granted when a regular bail

application is pending, ensuring that the accused does not remain in custody for an extended

period during legal proceedings. 1

Furthermore, this project will explore the criteria and factors that judges consider when

determining whether bail should be granted. The nature and gravity of the offense, the

accused's criminal history, the likelihood of the accused fleeing or tampering with evidence,

and the impact on the victim are some of the crucial elements weighed in this decision-

making process. By examining these factors in-depth, we aim to provide a nuanced

understanding of how bail determinations are made within the framework of the Criminal

Procedure Code.

In conclusion, bail is an indispensable component of our criminal justice system, symbolizing

the delicate balance between individual rights and societal interests. The various types of bail

recognized under the Criminal Procedure Code serve as mechanisms to safeguard the rights

of the accused while upholding the principles of justice and fairness. This project endeavors

to shed light on the intricacies of bail, the legal criteria governing its grant or denial, and its

broader implications within the criminal justice landscape. By delving into this complex

1
Janak Raj Jai, Universal’s Bail (Universal Law Publishing 2009).

6
subject matter, we hope to equip readers with a comprehensive understanding of the

multifaceted world of bail under the Criminal Procedure Code.

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 ORIGIN

Bail, a fundamental concept in modern legal systems, has roots in ancient Roman law, and

has evolved over centuries to the refined concept of bail in modern law.

The concept of bail has its roots in ancient civilizations. In ancient Mesopotamia, around

2100 BCE, the Code of Ur-Nammu allowed accused individuals to provide a personal surety

or pledge of property to secure their release. Ancient Roman law also recognized a similar

practice known as "pignus" or "vadimonium," where a person could provide a pledge or a

bondsman to vouch for their appearance in court.

During the medieval period, bail began to take on a more recognizable form in Europe. The

English legal system, in particular, played a significant role in its development. By the 13th

century, bail was used to secure the release of accused individuals, but it was often an

informal process involving friends or family members acting as sureties. If the accused failed

to appear in court, the sureties could be held responsible. 2

The 17th century brought about a more structured approach to bail with the introduction of

the recognizance system in England. Recognizance involved the accused and sureties

appearing before a judge and pledging a sum of money as security for the accused's

appearance at trial. Failure to appear would result in forfeiture of the pledged amount.

As European legal systems evolved, so did their approach to bail. This evolution significantly

influenced the development of bail in the United States. Early American colonies adopted

English common law practices, including bail, which laid the foundation for the Eighth

Amendment to the U.S. Constitution.

2
Devansh Bansal, ‘CONCEPT of BAIL: A HISTORICAL PERSPECTIVE’ (brain booster21 February 2022)
<https://www.brainboosterarticles.com/post/concept-of-bail-a-historical-perspective> accessed 30 September
2023.

8
In the 19th century, the concept of bail bonds emerged in the United States, allowing

defendants to secure their release by paying a percentage of the bail amount to a bail

bondsman. This practice became widespread, enabling many accused individuals to secure

their freedom even if they couldn't afford the full bail amount. Today, the bail system in many

countries, including the United States, has become more complex. Courts often consider

various factors, such as the nature of the crime, the defendant's flight risk, and their ties to the

community, when setting bail. Additionally, alternatives to monetary bail, such as pretrial

services and electronic monitoring, have gained prominence to address concerns about the

fairness of the bail system.

BAIL IN INDIA

The concept of bail in India has ancient roots. Ancient Indian legal texts like the Manusmriti

and Arthashastra mention provisions for release on bail. During British colonial rule, the

Indian Penal Code of 1860 introduced provisions for bail, although they were often

influenced by English common law practices.

With India's independence in 1947 came the drafting of a new Constitution, which sought to

establish a democratic and just society. The Constitution of India, adopted in 1950, played a

pivotal role in shaping the concept of bail. It enshrined several fundamental rights, including

the right to personal liberty and the presumption of innocence, which had a direct bearing on

bail procedures.3

The Indian judiciary, through various landmark decisions, has played a significant role in

shaping the bail system. The Supreme Court of India, in cases like Gudikanti Narasimhulu v.

3
‘Jurisprudence of Bail in India - Civilsdaily’ (CivilsDaily30 August 2022)
<https://www.civilsdaily.com/news/jurisprudence/> accessed 30 September 2023.

9
Public Prosecutor4 and State of Rajasthan v. Balchand5 , emphasized the importance of

individual liberty and the need for a liberal approach towards bail.

The Criminal Procedure Code (CrPC) is the key legislation governing bail in India. Post-

independence, significant amendments were made to the CrPC to align it with the principles

enshrined in the Constitution. Sections 436 and 437 of the CrPC lay down provisions for

granting bail to accused individuals. Post-independence India has witnessed a shift in bail

policies. There is now a greater emphasis on reducing pretrial detention and ensuring that bail

is the rule rather than the exception. The Law Commission of India, in its various reports, has

recommended reforms to make bail more accessible, especially for those who are

economically disadvantaged.

A significant challenge in the evolution of bail in India post-independence has been striking a

balance between individual liberty and public safety. While the courts have recognized the

importance of granting bail, they have also had to ensure that accused individuals do not pose

a threat to society or interfere with the legal process. In recent years, India has witnessed

several reforms aimed at modernizing the bail system. These include the use of technology

for risk assessment, the establishment of special courts to expedite bail hearings, and the

introduction of anticipatory bail provisions in certain cases. 6

Overall, it can be said that the concept of bail has a rich and diverse history, evolving from

ancient practices rooted in Mesopotamia and Rome to the modern systems we have today.

Over the centuries, bail has undergone significant changes, driven by the need for fairness

and justice in legal proceedings. While the core principle of bail remains the same – securing

the appearance of the accused at trial – the mechanisms and considerations involved in bail

4
AIR 1978 SC 429
5
AIR 1977 SC 2447
6
Urvashi Saikumar, ‘Indian System of Bail - Anti Poor - Bail Law in India’ (www.legalserviceindia.com)
<https://www.legalserviceindia.com/articles/bail_poor.htm> accessed 30 September 2023.

10
decisions have transformed to adapt to the needs of contemporary society. As we continue to

address issues of equity and fairness in the criminal justice system, the evolution of bail

remains a crucial aspect of that ongoing conversation.

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 TYPES OF BAIL

Within the Code of Criminal Procedure, various situations are enumerated with regards to

bail. While bail is classified mainly on the basis of at which point the legal proceedings are,

there is a further classification as regards the nature of the offence. For the purposes of

granting bail, offences have been classified into ‘Bailable offences’ and ‘Non-Bailable

offences’.

REGULAR BAIL

Regular bail, i.e., bail granted in cases of bailable offences, is the most common form of Bail

which is usually obtained by an accused. It is also the type of bail most people refer to when

they use the generalized term ‘Bail’. Regular Bail is the mechanism by which a competent

court can order the release of someone who is in detention on suspicion of committing an

offence, i.e., an accused, generally on the condition that the accused does not leave and fully

cooperates with the authorities in the course of investigation. These conditions may require

the execution of a “personal bond” or a court may compel the execution of a bond with

sureties.7

Section 436 of the Code of Criminal Procedure, 1973 contains the provision for regular bail.

Section 436 says-

7
Sneha Mahawar, ‘Types of Bail’ (iPleaders18 January 2023) <https://blog.ipleaders.in/types-of-
bail/#Anticipatory_bail> accessed 30 September 2023.

12
 “In what cases bail to be taken.—(1) When any person other than a person accused

of a non-bailable offence is arrested or detained without warrant by an officer in

charge of a police station, or appears or is brought before a Court, and is prepared at

any time while in the custody of such officer or at any stage of the proceeding before

such Court to give bail, such person shall be released on bail.”

Further, Section 436 also places certain conditions which the accused must fulfill in order to

secure bail-

“Provided that such officer or Court, if he or it thinks fit, [may, and shall, if such

person is indigent and is unable to furnish surety, instead of taking bail] from such

person, discharge him on his executing a bond without sureties for his appearance as

hereinafter provided.”

Although the normal procedure is for the accused to furnish securities for his/her bail to be

granted, this proviso in section 436 empowers the Court to grant bail to the accused only on

executive bond without needing securities if the accused is indigent or if the Court feels the

need, in any such case. In Aftab Ahmed v. State of UP8, the Court allowed the accused to be

granted bail only on executing a bail bond and without any sureties.

BAIL IN CASE OF NON-BAILABLE OFFENCES

Section 437 deals with the granting of bail for non-bailable offences. It provides discretionary

powers to the Courts to decide whether or not they want to grant bail to an accused. However,

this discretion granted by section 437 is not without certain requirements, to be fulfilled by

8
1990 CriLJ 1636

13
the accused, that the court must keep in mind while granting bail to persons accused of a non-

bailable offence.

According to Section 437(1) –

“When bail may be taken in case of non-bailable offence.— [(1) When any person

accused of, or suspected of, the commission of any non-bailable offence is arrested or

detained without warrant by an officer in charge of a police station or appears or is

brought before a Court other than the High Court or Court of session, he may be

released on bail.”

The section further goes on to innumerate the various conditions, failing which, the court may

not grant bail to the accused. Following are the conditions-

1. Such person shall not be released if there appear reasonable grounds for believing that

he has been guilty of an offence punishable with death or life imprisonment.

2. If such offence is a cognizable offence and the accused had been previously convicted

of an offence punishable with death, imprisonment for 7 years or more, or he had

been earlier convicted on two or more instance of a non-bailable and cognizable

offence.

3. The court may still grant bail to a person referred to under (1) and (2) if they are under

16 years of age, a woman, sick or infirm.

4. The court may also grant bail to a person referred to under (2) if it is satisfied that it is

just and proper so to do for any other special reason.

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 5. The court may also grant bail to an accused who is required to be identified by

witnesses, in the due course of investigation, as long as he is otherwise entitled to bail

and undertakes to comply with the investigating authorities.

Clause 6 of section 437 provides that if, in any case triable by a Magistrate, the trial of the

accused is not concluded within 60 days since the institution of the case, then the Magistrate

shall order the release of the accused on bail if the accused was in custody during the whole

of this period of 60 days. And clause 7 of section 437 states that if, after the conclusion of the

trial of an accused and before delivery of judgment, the Court feels that the accused is not

guilty of any offence for which he was being tried, then the accused shall be released from

custody on execution of a bond without sureties, for his appearance to hear the judgment

delivered.

15
ANTICIPATORY BAIL

Anticipatory bail, as the name suggests, is bail granted to a person in anticipation of, and

apprehending arrest. When a person has reason to believe that he may be arrested on the

accusation of committing a non-bailable offence then he can move to High Court or the Court

of Session u/s 438 of CrPC for anticipatory bail. The very purpose for the provisions relating

to anticipatory bail is to ensure that no person is confined in any way until and unless held

guilty. 9

Anticipatory bail is a form of bail that one may obtain from a competent court prior to arrest

and detention by the police. Unlike regular bail, anticipatory bail is obtained before one is

arrested and it comes into effect as soon as the accused is arrested and/or detained.

Section 438 of the CrPC deals with the issue of anticipatory bail. It says-

“Direction for grant of bail to person apprehending arrest.—(1) When any person

has reason to believe that he may be arrested on an accusation of having committed a

non-bailable offence, he may apply to the High Court or the Court of Session for a

direction under this section; and that Court may, if it thinks fit, direct that in the event

of such arrest, he shall be released on bail.”

The rationale behind the concept of Anticipatory bail is mainly to protect citizens from

frivolous and often times, falsely and maliciously filed complaints against them by other

parties. It would be easy to throw one’s life into disarray by simply accusing someone of a

crime, filing an FIR and having them arrested since the mere act of getting arrested, even if

9
Vaish Associates Advocates-Vijay Pal Dalmia, ‘Anticipatory Bail Law in India’ (Lexology12 November 2021)
<https://www.lexology.com/library/detail.aspx?g=65663229-cd14-4f1b-ab9b-0bc4965dee55> accessed 30
September 2023.

16
later acquitted, can cause great mental anguish, physical harm and loss of employment

opportunities.10

The 41st Law Commission Report of 196911 observed that-

“The necessity for granting anticipatory bail arises mainly because sometimes

influential persons try to implicate their rivals in false cases for the purpose of

disgracing them or for other purposes by getting them detained in jail for some days.

In recent times, with the accentuation of political rivalry, this tendency is showing

signs of steady increase.”

Section 438 of the CrPC contains within it, certain conditions and elements that must be

present for the accused to be granted anticipatory bail. The court is expected to base their

decision on the following factors, when granting bail u/s 438-

1. The nature and gravity of the offence which the accused has been charged with;

2. Whether the applicant has previously undergone imprisonment or been accused of any

cognizable offence;

3. The possibility of the accused fleeing from justice; and

4. Whether the accusation has been made with a view to to injure or humiliate the

applicant by having him so arrested.

10
Sneha Mahawar, ‘Anticipatory Bail’ (iPleaders26 September 2022) <https://blog.ipleaders.in/anticipatory-
bail/>.
11
Para 39.9, 41st Law Commission Report, 1969.

17
In the case of State of Madhya Pradesh v. Pradeep Sharma12, the Apex court observed that

where an accused has been designated an absconder under section 82 of the CrPC and has

failed to cooperate fully with the investigation, he/she shall not be granted anticipatory bail.

Consequently, there are certain criteria that must be met in order to get anticipatory bail-

1. The individual makes himself available for questioning by a police officer as

needed;

2. The individual must not, directly or indirectly, provide any enticement, threat, or

promise to any person familiar with the facts of the case in order to persuade him

not to disclose such details to the court or any police officer;

3. The individual should not depart India without the court’s prior approval.

12
(2014) 2 SCC 171

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INTERIM BAIL

Interim bail is another type of bail that may be issued by a court to the accused whilst a bail

application, for anticipatory or regular bail, is ongoing and being heard by the court. It is

separate from regular bail and even anticipatory bail, in the sense that it is much quicker and

a completely temporary release. Application for a regular or anticipatory bail may take

certain days or even weeks or perhaps even months to be heard and disposed of, or granted.

Meanwhile, the loss of reputation and mental anguish suffered by the accused would be

certain. Hence, to ensure there is no needless detention due to the time consuming legal

process of getting regular bail, there exists the option for the court to grant interim bail to the

accused and release him from custody until the actual bail application has been disposed of. 13

It is important to note that interim bail is not indefinite and is granted for a short period of

time, usually to cover the time it would take to hear and dispose of the bail application.

However, if the period of interim bail expires and the bail application has not yet been

decided upon, the accused may be arrested and placed back in custody.

Unlike other forms of bail, interim bail does not have a section under the CrPC. However, it

is understood to constitute an inherent power of the court to grant interim bail, provided that

the court sees it fit to grant it. A person’s reputation is a valued asset and is a component of

his or her right under Article 21 of the Indian Constitution. Consequently, it can be concluded

that the power to grant interim bail includes the inherent jurisdiction of the concerned court.

In the case of Sukhwant Singh & Ors. v. State of Punjab(1995)14, the Supreme Court

concluded that “the authority of the courts to give interim relief is inherent in their power to

13
Debashrita Manik, ‘Types of Bail under the Code of Criminal Procedure’ (StrictlyLegal15 July 2022)
<https://strictlylegal.in/types-of-bail-under-the-code-of-criminal-procedure/>.
14
1995 AIR 1380

19
grant bail. The idea of interim bail is significant because an accused may risk arrest even

before the verdict on his bail is issued. Interim bail is therefore granted when the court is

persuaded that it is necessary to safeguard the accused from being wrongfully arrested or

imprisoned.”

Further, in Lal Kamlendra Pratap Singh v. the State of U.P. and Ors (2009)15 the Court ruled

that “interim bail should be granted in appropriate circumstances while awaiting the outcome

of the final bail application because arrest and imprisonment could do irreparable harm to a

person’s reputation.”

Finally, in Parminder Singh and Ors. v. the State of Punjab (2001)16 the High Court of Delhi

laid out certain parameters under which interim bail may be granted. They stated that interim

bail may be granted in the following circumstances-

1. When there is no chance that the accused will escape prosecution; and

2. When there is no chance that the defendant will tamper with the evidence.

3. When there is no justification for constrained questioning, and

4. When the anticipatory bail hearing must be rescheduled.

15
(2009) 4 SCC 437
16
95 (2002) DLT 410

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STATUTORY BAIL

When a person is detained without a warrant, the police are obligated to bring him before a

magistrate if the inquiry is not concluded within 24 hours and to complete the investigation

without undue delay. If the investigation is not concluded within a certain time period, the

accused accrues the right to be released through statutory bail. 17

Statutory bail, also often referred to as mandatory or default bail, is a legal right, for the

accused who is in custody, that arises and becomes enforceable when the police fail to finish

the investigation, in the accused’s case, within a certain time frame. Contained within section

167(2) of the CrPC, it provides that no Magistrate shall authorise the detention of the accused

person in custody beyond-

1. Ninety days, if the offence that the accused is charged with is punishable with death,

imprisonment for life or for a term not less than ten years;

2. Sixty days, for any other offence other than the ones described above.

On the expiration of this period of sixty or ninety days, as the case may be, the accused shall

be granted bail and released from custody, if he is willing to, and does, furnish bail. It is to be

noted that right to statutory bail is a legal entitlement, despite the nature or severity of the

crime and that the period from which sixty or ninety days are to be counted begins on the date

that the accused is detained and held in custody.

17
Nupur, ‘Bail Explained under Sections 436 to 450 of CrPC’ (WritingLaw19 November 2021)
<https://www.writinglaw.com/bail-under-crpc/> accessed 30 September 2023.

21
In the case of Bikramjit Singh v. State of Punjab (2020)18 the Supreme Court held that “the

accused has an inalienable right to “default bail” if he applies after the stipulated term for

investigation of an offence has expired but before a charge sheet is submitted.” Further, they

iterated that the right to statutory bail u/s 167(2) is not just a legislative right, but also an

inherent part of the legal system created under Article 21 of the Indian Constitution. And that

statutory bail is an ‘unalienable right’.

It is clear from a bare reading of Section 167 that the accused shall be released from custody

if the accused exercises his right to default bail. In other words, although statutory bail

becomes legally enforceable automatically upon the expiration of the time period, it will not

be applicable until and unless the accused exercises his right to default bail and

communicates the same, either written or even orally.

18
10 SCC 616

22
 CONCLUSION

In the intricate tapestry of the criminal justice system, the concept of bail stands as a thread

that weaves together the principles of liberty, fairness, and public safety. As we conclude our

exploration of bail, we find ourselves at a juncture where empathy, optimism, and reform

intersect to redefine its role in the pursuit of justice. The evolution of bail in law reflects our

ongoing struggle to strike a balance between individual liberties and collective security. This

delicate equilibrium has been tested, sometimes to the breaking point, in societies across the

world. Yet, it is precisely these challenges that have driven us to rethink and reform the bail

system.

The past has taught us that bail should never be a privilege reserved for the wealthy or well-

connected. It should not perpetuate cycles of poverty or unfairly burden marginalized

communities. Instead, our collective empathy has led to the recognition that bail reform is not

just a legal issue; it is a moral imperative. As we look back at the development of bail,

particularly in the wake of independence movements and the establishment of democratic

principles in many nations, it becomes evident that our legal systems have made significant

strides. Constitutions, like the one in India, explicitly affirm the right to personal liberty and

the presumption of innocence. These principles serve as guiding stars, illuminating a path

towards a more just and empathetic bail system.

Landmark judicial decisions, such as those in the United States and India, have underscored

the paramount importance of individual liberty and the need for a liberal approach to bail.

Judges, imbued with wisdom and empathy, have played a pivotal role in ensuring that justice

is not delayed, and those deserving of bail can obtain it swiftly.

23
Moreover, contemporary reforms have allowed us to leverage technology, risk assessment

tools, and alternative forms of pretrial supervision. These innovations provide us with the

means to make bail not just a matter of monetary value but a reflection of a person's risk to

society.

Our optimism lies in the belief that bail reform is not an insurmountable challenge. It is a

shared commitment to fairness, justice, and empathy. It is a belief that we can craft a future

where bail serves as a true instrument of justice, unburdened by prejudice or inequality. It is a

conviction that we can reimagine bail as a system that uplifts and rehabilitates, rather than

one that punishes and isolates.

In conclusion, our journey through the history and evolution of bail demonstrates that change

is possible, and it is within our grasp. As we stand at this crossroads, let us choose a path

illuminated by empathy, guided by optimism, and paved with the principles of justice and

fairness. The reimagining of bail is not just a legal endeavor; it is a testament to our

commitment to a brighter and more equitable future. Let us take this opportunity to shape a

world where bail truly serves as a beacon of hope, reflecting the better angels of our nature

and our unwavering dedication to the pursuit of justice.

24
 BIBLIOGRAPHY

1. Janak Raj Jai, Universal’s Bail (Universal Law Publishing 2009).,

2. Devansh Bansal, ‘CONCEPT of BAIL: A HISTORICAL PERSPECTIVE’ (brain

booster21 February 2022) <https://www.brainboosterarticles.com/post/concept-of-

bail-a-historical-perspective> accessed 30 September 2023.,

3. ‘Jurisprudence of Bail in India - Civilsdaily’ (CivilsDaily30 August 2022)

<https://www.civilsdaily.com/news/jurisprudence/> accessed 30 September 2023.,

4. Nupur, ‘Bail Explained under Sections 436 to 450 of CrPC’ (WritingLaw19 November

2021) <https://www.writinglaw.com/bail-under-crpc/> accessed 30 September 2023.,

5. Sneha Mahawar, ‘Types of Bail’ (iPleaders18 January 2023)

<https://blog.ipleaders.in/types-of-bail/#Anticipatory_bail> accessed 30 September

2023.,

6. Dalmia VAA-VP, ‘Anticipatory Bail Law in India’ (Lexology12 November 2021)

<https://www.lexology.com/library/detail.aspx?g=65663229-cd14-4f1b-ab9b-
0bc4965dee55> accessed 30 September 2023

7. Sneha Mahawar, ‘Anticipatory Bail’ (iPleaders26 September 2022)

<https://blog.ipleaders.in/anticipatory-bail/>.,

8. Debashrita Manik, ‘Types of Bail under the Code of Criminal Procedure’

(StrictlyLegal15 July 2022) <https://strictlylegal.in/types-of-bail-under-the-code-of-
criminal-procedure/>.,

9. Urvashi Saikumar, ‘Indian System of Bail - Anti Poor - Bail Law in India’
(www.legalserviceindia.com)
<https://www.legalserviceindia.com/articles/bail_poor.htm> accessed 30 September
2023.

25