This is a criminal revision petition filed by Dawood challenging the concurrent judgments convicting him under Section 292(2)(a) IPC for displaying obscene books for sale. The Trial Court convicted him for selling obscene material and sentenced to three months’ simple imprisonment; the Appellate Court confirmed the conviction but reduced the sentence to 15 days and imposed a fine of Rs. 2,000 with an additional 15-day imprisonment in default. Dawood contends that the prosecution failed to prove his possession of the shop room from which MOs 1–5 were seized and that the books themselves were obscene; he relies on Konnadan Abdul Gafoor v. State of Kerala (2016) to bolster the claim that possession and obscenity must be established with proof beyond the seizure of the books. The State contends that although PWs did not testify the books as obscene, the courts below examined and found them obscene; the revisional court should not interfere. The Court discusses the standard for obscenity (historical Hicklin test vs. community standard) and emphasizes that the onus to prove all ingredients lies on the prosecution. It ultimately hold that the prosecution failed to prove possession and obscenity and thus allows the revision petition, setting aside the conviction and sentence, cancelling bail bonds, and directing refund of any deposited fines, with compliance to the Trial Court.
This writ petition (C) challenges the Kerala Act of 1999 restricting transfers by and restoration of alienated lands by members of Scheduled Tribes. Petitioners, residents of Tamil Nadu, contend that their property at Kanarpalayam (Exts. P4 and P5) falls outside the 1999 Act’s ambit and seek a declaration to that effect, along with police protection to enjoy and move through their land. The respondents, including the State and local officers, claim the 1999 Act applies to transfers and seeks to protect tribal interests, noting prior transfers and the involvement of tribal documents and ignorance. The 1999 Act provisions specify that transfers by a member of a Scheduled Tribe to non-members after commencement are invalid (Section 4) and pre-commencement transfers between 1960 and the Act’s start may be valid if under 2 hectares (Section 5(1) and the proviso). The court examines Exts. P4 (1997) and P5 (1975) showing a total extent of 3.04 acres (about 1.23 hectares), which is below the 2-hectare limit, thus not falling within invalidity. It rejects the respondents’ reliance on other arguments and emphasizes statutory clarity over extrajudicial remedies. Citing Harrison’s Malayalam and Jithesh, the court holds that the petitioners are entitled to relief and declares the properties not governed by the 1999 Act, granting police protection and protection of movement. The petition is allowed with consequential orders to protect the petitioners’ possession and rights.
N. J. Sebastian, the petitioner, owns 24.420 cents of land in Chengalam East Village, Kottayam Taluk, with a residential building rebuilt in 2009-2010. The building’s plinth area is claimed by the petitioner to be 276.57 sq m, while the assessing authority (the Tahsildar) determined a plinth area of 301.57 sq m and levied building tax under Section 5 of the Kerala Building Tax Act, 1975, plus luxury tax under Section 5A (as it stood before 1.4.2014). The appellant disputes including a temporary shed appurtenant to the main building in the plinth area calculation, arguing it is not part of the building’s use area for tax purposes. Exts. P2–P4 document the assessment, demand and luxury tax levy. The petitioner challenged Exts. P2, P3 and P4 by filing, first, an appeal under Section 11 before the RDO (Ext. P7) and, thereafter, a revision under Section 13 before the District Collector, seeking condonation of delay for the revision. The District Collector dismissed the revision primarily for delay, holding that the 30‑day period could not be extended. The High Court examined the revisional power, limits of condonation, and the applicability of the Limitation Act to quasi‑judicial authorities, citing several precedents. Ultimately, the Court quashed the luxury tax order (Ext. P4) under Section 5A and directed a merits‑based reconsideration of the plinth area excluding the appurtenant structure, with notice, within three months, and directed determination of liability for subsequent periods; remitted taxes, if any, would be refunded. The writ petition was disposed of without costs.
This Motor Accident Claims Appeal arises from a tribunal judgment in OP(MV) No.307/2015, Muvattupuzha, concerning the death of Madhu in a motor vehicle collision on 06.02.2014 involving a tourist bus insured by the appellant insurer. The respondents 1–3 (ShyLaja, Akshara Madhu, and Keerthana Madhu) and the 4th respondent (Prasanth R.G.) claimed compensation for the death of Madhu, who was 51 and employed as a driver with a claimed monthly income of Rs. 10,000. The MACT tribunal found the bus driver negligent, and the insurer liable, but held that the policy conditions were violated because the driver lacked a valid driving license. It awarded Rs.10,79,838 with 6% interest from the petition date and directed deposit; if not deposited within five months, 9% interest would apply. The insurer challenged the award in MACA No.1590/2018. The High Court relied on Ext.A6 police final report and Pazhaniammal to accept police findings in the absence of contrary evidence. It upheld the driver’s negligence and addressed quantum: rejecting arguments to alter monthly income, citing Manusha Sreekumar for 2015 wage norms while noting the accident occurred in 2014, and allowed a modest adjustment to pain, suffering, and loss of consortium heads. The court ultimately modified the award by removing the penal interest clause and directing deposit with 7% interest, within three months.
Ex.FA Nos.9/2021, 11/2021, 12/2021, 13/2021, 14/2021, 15/2021 These six execution first appeals arise from a common order of the trial court under Order 21 Rule 58 CPC, lifting attachments on properties of claimants in execution proceedings. The original decree was passed by the Bombay High Court and later transmitted to the Kerala District Court, Thrissur, for execution in the state. The six claimants claimed right, title and interest in properties seized by attachment in 2019, long after the transfers alleged by the claimants in 2012. The decree holder argued that relief under Section 53 of the Transfer of Property Act should be available to challenge or defeat the claim of title on grounds of long-delayed attachments; counsel relied on the principle in Shriman Shamrao Suryavanshi v. Pralhad Bhairoba Suryavanshi to contend that limitations cannot bar a defence, especially when an attachment is maintained to secure the decree’s execution. The appellants argued that the protective attachment should be treated as a shield against loss of value to the decree. The Kerala High Court, however, distinguished the cited decision, holding that an attachment under Order 21 Rule 58 is a protective measure to secure execution rather than a substantive defence under Section 53; belated invocation of Section 53 cannot defeat the rights of purchasers who have transferred title years earlier. It held there is no scope to apply limitation principles to the protective attachment, and hence the common order lifting the attachments should stand. Consequently, all six appeals were dismissed, without costs.
This is an original civil petition (OP(C) No.792 of 2020) filed before the High Court of Kerala at Ernakulam by Pradeep Kumar and Sree Devi V.G. against an order in IA 5/2020 in OS 256/2019 of the Munsiff Court, Changanacherry. The petitioners, husband and wife, are co-owners of plaint schedule items 1 and 2, with item 3 belonging to the respondents. A narrow path (item 4) along the western boundary provides access to items 1 and 2; its use was protected by an ad-interim injunction (Ext P3). An Advocate Commissioner’s report (Ext P5) measured item 4 as 75 feet long and 9 feet wide, while later developments showed the width reduced by a new retaining wall (Ext P15). The petitioners sought to demolish the retaining wall and restore the status quo ante by moving Ext P16 (an interlocutory application) and challenged the lower court’s Ext P18 order, which dismissed Ext P16. They argued that the last non-contested status, as recorded in Ext P5, should be preserved; the construction of the retaining wall violated Ext P3 and could cause irreparable harm. The respondents maintained that the issue required evidence and should be decided after due process, opposing early demolition. The High Court relied on a Supreme Court decision to outline guidelines for interlocutory mandatory injunctions, and ultimately allowed the petition, setting aside Ext P18 and directing the lower court to reconsider Ext P16 in light of the law, with a one-month timeframe for disposal.
The petitioner tenant in EP 15/2023 under RC OP 31/2018 filed this original petition under Article 227 seeking to restrain eviction and to defer execution until Ext.P8 CF 1914/2023 is disposed of. The Rent Control Court had earlier granted eviction under Sections 11(2)(b) and 11(3) of the Kerala Buildings (Lease and Rent Control) Act, 1965, on 29 February 2020; RC Appeal No. 6 of 2021 was dismissed for non-prosecution on 9 December 2022. The petitioner sought supervisory relief from the High Court to adjourn the execution proceedings listed for 3 March 2023 pending Ext.P8; the landlord contended for eviction and argued that the execution petition should proceed, and that the appeal had already ended. The High Court explained that Article 227 powers are supervisory and should be exercised with restraint, to maintain efficiency and public confidence in the justice system, and not as a general correctional tool. It held that the petition was an abuse of process and not a proper use of Article 227. Consequently, the petitioner withdrew the petition and the court dismissed the matter with costs.
MACA Nos. 2600/2022; 473/2020; 470/2020; 478/2020; 2104/2022; 2597/2022 On 03.09.2015, Tap an Mistri, Rejjak Shekh, and the deceased Fajlu Gazi were travelling in a mini-lorry owned by their employer when the vehicle toppled due to the driver’s rash driving. Tap an Mistri and Rejjak Shekh sustained injuries, while Fajlu Gazi died, leading to OP(MV) Nos. 1376/2017, 1378/2017 and 1377/2017 before the Motor Accidents Claims Tribunal, Kozhikode. The Tribunal awarded compensation: Rs.5,27,000 to Rejjak Shekh, Rs.1,05,000 to Tap an Mistri, and Rs.23,66,000 to the deceased’s legal heirs (Rs.40 lakhs claimed). National Insurance Company Ltd. challenged liability, contending the injured and deceased were gratuitous passengers on the cargo platform; the owner-cum-driver maintained they were employees and inside the cabin. The High Court disposed six connected appeals in a single judgment, upholding most findings and enhancing several heads of compensation: loss of amenities for Tap an Mistri increased; pain and suffering for Rejjak Shekh raised; extra nourishment adjusted; and the notional income fixed at Rs.10,000 per month with 10% uplift for future prospects per Pranay Sethi and Ramachandrappa. The insurer was permitted to recover enhanced amounts from the owner after satisfying claimants, and deposits were directed within two months at 8% interest. The judgment clarifies policy coverage under a Package policy and rejects the cargo-platform argument, while confirming most Tribunal conclusions.
This is a criminal revision petition under sections 397 and 401 CrPC filed by Tom Jose (Accused No.2) challenging a discharge order in SC No.542/2016 before the Additional Sessions Court, Thalassery, arising from a fatal bus-accident involving a four-year-old child on 15 July 2015 in Payyavoor. The school bus, belonging to Cherupushpa U.P. School, was carrying children home when the hydraulic door allegedly malfunctioned and opened, causing the child to fall and the rear wheel to run over him, resulting in death. The charge sheet initially charged the driver and the petitioner under Section 304 read with 34 IPC. The petitioner contends he had no control over the vehicle or its door and that there was no positive act by him amounting to an offence; at most, he could have been negligent, which cannot alone attract culpability under Sections 299/304 IPC. The Sessions Court dismissed his discharge application under Section 227 CrPC, prompting this revision. The court examined Annexure A2 (Motor Vehicles Inspector) showing the door’s malfunction and a certificate from the Head Master indicating the petitioner’s deployment to supervise children in the bus. Citing Union of India v. Prafulla Kumar Samal, the court reiterates the criteria for framing charges and discharge. It concludes there are no grave ingredients against the petitioner and allows the revision, discharging him from the case.
This is a criminal revision petition filed under CRL.R.P. No. 2335 of 2009 before the Kerala High Court by two accused, Shibu Jacob and Johnson Mathew, challenging an order/judgment in CRA 81/2003 arising from CC 243/1997 before the Judicial Magistrate of First Class, Thalassery. The prosecution alleged offences under Rule 6 of the Kerala Rectified Spirit Rules r/w Section 55(a) of the Kerala Abkari Act for storing rectified spirit in 20 plastic barrels and 4 plastic cans at House AP II 557(A) Maniyur desom on 12.08.1996. The trial court convicted the accused to two years’ simple imprisonment and imposed a fine of Rs.25,000 each with default imprisonment. The Sessions Court dismissing the appeal upheld the conviction. In revision, the petitioners argued multiple procedural lapses: unexplained two-day delay in producing Ext. P1 (the seized contraband) before the court, absence of specimen seals, non-production/marking of the forwarding note, and that the investigation was conducted by an Assistant Sub-Inspector (not empowered under the Goverment Order/Abkari provisions). They relied on SRO 321/96 and decisions including Sabu v. State of Kerala. The court emphasized strict compliance with Abkari formalities, noted that unexplained delay and missing seals undermine chain-of-custody and the linkage between seized material and laboratory analysis, and ultimately acquitted the petitioners, setting aside lower courts’ verdicts. The bail bonds were cancelled and the accused were set at liberty.
Cont.Case (C) No. 609 of 2020 The contempt petition under Section 12 of the Contempt of Courts Act, 1971 arises from W.P.(C) No. 584/2017 decided on 12 October 2018, and concerns alleged willful disobedience of Annexure A1 directions in the Employees Provident Fund Organisation pension matter. Petitioners (petitioners 1, 3, 4 and 6–11) claim that the higher pension as directed by the 2018 judgment should be disbursed under the amended pension scheme (post-2014) and that the EPFO has persisted in non-compliance. The Supreme Court’s 2022 judgment in Employees Provident Fund Organisation v. Sunil Kumar B. upheld the legality of the 2014 amendment (G.S.R. 609(E)) and laid down guidance on option exercise, pension computation, and transitional terms (paragraphs 11(3) and 11(4)), directing authorities to implement accordingly and extend options where needed. The Kerala High Court, noting the apex decision, held that petitioners’ entitlement for higher pension requires reconsideration by EPFO and directed such reconsideration, within eight weeks, in line with the Supreme Court’s judgment. The Contempt Case is closed, with liberty to EPFO to reconsider entitlement under law in view of the 2022 apex judgment; the court retained jurisdiction to ensure compliance of directives under the amended scheme.
CRL.R.P. No.1457/03; Crl.R.C. No.4/15 This High Court of Kerala revision concerns the death of an 11-year-old girl following a penicillin injection administered at J.K. Hospital, Pampanar, in 1991. The first accused, a doctor, and the second accused, a nurse, were charged with offences under IPC sections 304 Part II (culpable homicide not amounting to murder), 419 and 420 read with 34, and 15(2)(b) of the Indian Medical Council Act, 1956. After trial, the Assistant Sessions Court convicted them and sentenced them to seven years’ rigorous imprisonment and fines. On appeal, the Sessions Court partially allowed the appeal: the second accused was acquitted; the first accused’s conviction under 304 Part II IPC was altered to 304A IPC, with the sentence maintained. The High Court, suo motu, initiated proceedings to restore the original 304 Part II conviction. It held that there was no merit in restoring 304 Part II as there was no conclusive proof that the first accused lacked qualification to practice medicine, though it found gross negligence in his treatment, which justified the 304A conviction. The Court clarified that the “maintained” sentence under 304A means the maximum two years’ imprisonment, and therefore dismissed both revision petitions while affirming the 304A conviction. The judgment emphasizes careful medical practice, proper use of Section 313 Cr.P.C, and limits on sentencing under 304A IPC.
This writ petition (W.P(C).7458/2021) was filed by Disha, a non-governmental organisation, on behalf of the Chakkiliyan Scheduled Caste community of Puthur Grama Panchayat, Palakkad, seeking mandamus and directions to ensure a law-and-order environment around a burial ground and to permit burial of the deceased belonging to the Chakkiliyan community at the public burial ground. The petitioner alleged caste-based discrimination, claiming that members of the Chakkiliyan community were denied access to cremation and burial facilities at Alamaram (later named Sivasakthimaya) cremation ground and that dominant castes threatened and restrained bereaved families. The petition invoked Articles 15, 17 and 21 of the Constitution, arguing that denial of burial access violated equality, abolition of untouchability, and the right to life with dignity even in death, supported by provisions of the Protection of Civil Rights Act, 1955 (Sections 4 and 15A) and the Kerala Panchayat Raj (Burial and Burning Grounds) Rules, 1998. The respondents (State, District Collector, Panchayat authorities, police officials, and SC/ST Commission) denied systematic discrimination, explaining incidents during COVID-19 fears and referencing separate burial grounds for various communities. The court ordered counter-affidavits and directed disclosure of private burial grounds and related details, while ultimately disposing of the petition with directions to consider licensing and policy reforms, reiterating the need for dignity and equal access in burial rights.
Kanakamma, the revision petitioner in CRL.R.P. 944 of 2006, appeals against a conviction under Section 58 of the Abkari Act recorded by the Judicial Magistrate of First Class, Adoor, and affirmed by the Additional District & Sessions Judge (Ad-hoc), Pathanamthitta. The alleged offence occurred on 29 March 1996 when she was found carrying four litres of illicit arrack in a plastic jar on a panchayat road; the seizure was effected by PW1, with PW3 registering the crime and producing exhibits. The trial court convicted her, sentencing three months’ imprisonment and a fine of Rs 15,000, with a default sentence. The appellate court dismissed the appeal, maintaining the conviction. In the High Court revision petition, the Court, noting difficulties in tracing the trial records, proceeded on the merits with copies supplied by the counsel. The petitioner’s counsel argued material irregularities: the detecting officer could not be examined because he was no longer alive; the seizure mahazar lacked a specimen impression of the seal; there was no forwarding note or arrest memo; independent witness PW2 deposed unfavorably. Relying on Bhaskaran K. v. State of Kerala (2020), Ajayakumar v. State of Kerala (2021), Baburaj v. State of Kerala (2021) and Ramankutty v. Excise Inspector, Chelannur Range (2013), the court held that absence of seal specimen, forwarding note and arrest memo undermines the chain of custody and creates doubt about the prosecution’s case. Consequently, the accused is acquitted and discharged.
This is a criminal miscellaneous petition under section 482 CrPC filed by the petitioner, Saiby Jose Kidangoor, challenging Crime No.254/2023 registered at Cheranalloor Police Station against him (under IPC sections 406, 420, 506) on a complaint by the 3rd respondent. The complainant, an estranged spouse’s family, alleged that as the advocate for the wife, the petitioner offered to obtain favorable orders and withdraw cases in exchange for Rs 10 lakh, with a threat to block the complainant’s passport. The incident is said to have occurred on 15 December 2013, but the complaint was lodged only in March 2023, with a delayed disclosure of details and a long history of related professional disputes including Bar Council proceedings against the petitioner. The petitioner contends the allegations are false, concocted to harass him due to professional rivalries and his bid to become President of the Kerala High Court Association, and that the investigation is at an early stage. The respondent argues the complaint is credible and the case should proceed. The High Court, applying the principles governing quashing under 482 CrPC and considering the extreme delay, mala fides, and abuse of process, ultimately quashes Crime No.254/2023 and all further proceedings, allowing the petition.
This is a Criminal Revision Petition filed by HaneeFa challenging the judgment in Crl.A. No.211/2009 of the Additional Sessions Judge (Fast Track Court No.II), Palakkad, which affirmed the conviction and sentence recorded in CC No.291/2006 of the Judicial Magistrate of First Class, Pattambi. The prosecution case, dated 27.06.2002, alleges that two accused, in furtherance of their common intention, broke open the front door of a house at Anakkara Village (PW2’s residence) to commit theft, thus committing offences under IPC sections 454 (house breaking), 380 (theft), and 511 (attempt to commit theft) read with Sec.34. The trial court convicted the first accused under the cover of sections 511 read with 380, sentencing one year’s imprisonment and a fine of Rs. 1,000 with a default one-month imprisonment. The second accused was tried separately (CC 787/2002). On appeal, the Appellate Court dismissed the appeal and confirmed the conviction and sentence. The revision petition argues that the evidence, particularly DWs 1–3, contains glaring contradictions and does not prove guilt beyond reasonable doubt; further, the trial court allegedly did not put all incriminating circumstances to the accused under Sec.313 CrPC, rendering the trial vitiated. The State contends that concurrent findings are well-supported by the record. The High Court discusses the narrow scope of revisional jurisdiction, citing Sanjaysinh Ramrao Chavan to reinforce that revisional courts are not second appellate forums. Ultimately, the High Court sustains the concurrent findings and dismisses the revision petition, upholding the conviction and sentence.
WP(C) Nos.8448 & 19432 of 2021 The petition challenges Ext.P5 order of the KVAT Appellate Tribunal directing reassessment of VAT in respect of Pest Control contracts for the years 2008-09 to 2012-13, and Ext.P11 rejecting refunds sought for service tax already paid. The petitioner contends pest control work is a pure service contract and not a works contract; thus VAT would be unjustified where there is no transfer of goods. The respondents argue that, on existing precedents, pest control contracts involve sale of chemicals and are effectively works contracts taxable under KVAT, with service tax already collected. The Kerala High Court acknowledges the long-standing dispute on whether pest control contracts are service or works contracts, noting that several High Courts and the Supreme Court have addressed the issue. A pivotal reference is State of Gujarat v. Bharat Pest Control (2018), which held that such contracts can fall within works contract due to the element of sale of chemicals. The court also notes the principle that tax collection must be under authority of law and that refunds must follow statutory provisions (as per Mafatlal Industries). However, the court emphasizes that the contentions on facts require reassessment with due consideration to the specific contract terms. Consequently, while Ext.P5/Ext.P11 are not struck down, Ext.P13/Ext.P14 are set aside, and a fresh, reasoned assessment is to be carried out after hearing the petitioner, in continuation of Ext.P5.
CRL.REV.PET NO. 18 OF 2011 Veluswamy T.V., the revision petitioner, challenges a concurrent conviction and sentence arising from a 11 June 2000 road accident near Palappallam on a stage carriage bus that left one passenger dead and several injured. The trial court found him guilty of offences under IPC sections 279 (rash driving), 337 (causing hurt by endangering life), 338 (causing grievous hurt by endangering life) and 304A (death by negligence) and sentenced him to concurrent terms and fines. The Appellate Court dismissed the appeal, upholding the convictions and sentences. In revision, counsel for the petitioner contends that the eyewitnesses who testified against him were not uniformly credible; many witnesses denied seeing him drive rashly, and the prosecution’s reliance on a few witnesses with alleged interest is insufficient to sustain guilt beyond reasonable doubt. He argues that speed alone is not determinative of rashness and that the rainy conditions and the driver’s position complicate identification. The Public Prosecutor defends the verdicts, highlighting the testimony of PW7, PW31, PW33 and others, and contends that the driver’s overspeed and rash conduct caused the accident. The High Court, while acknowledging the need to exercise revision with caution, ultimately confirms the conviction but uses its power to modify the sentence, reducing it to three months’ simple imprisonment for each IPC section and imposing a fine of Rs.5,000 for 304A, with execution deferred to a specified date.
RSA No. 223 of 2023; RSA No. 395 of 2023 This is a Regular Second Appeal filed by Anil Kumar challenging the decrees of the Sub Court, Chengannur, in O.S. No.136/2013, where the plaintiff sought declaration of title to plaint A and B schedule properties and a permanent injunction restraining the defendants from obstructing a bakery business in plaint B schedule room. The trial court dismissed the plaintiff’s suit and decreed the counter-claim in favor of the first defendant, declaring title to counter-claim schedule item Nos.1 and 2 and directing possession of counter-claim item No.2, with no costs. On appeal, the first appellate court dismissed both appeals and confirmed the trial court’s decree and judgment. The defendants’ counter-claim was opposed by the plaintiff on the ground that it did not satisfy Order VIII Rule 6B read with Order VII CPC, i.e., it should be in plaint format containing prescribed particulars; the plaintiff argued omissions should render the counter-claim defective. The High Court framed questions on the requirements of filing a counter-claim and whether minor omissions can lead to non-suit at appellate stages, emphasizing that counter-claims may be filed under Order VIII Rule 6A(1) and are treated as plaints, with omissions being curable irregularities. Ultimately, the High Court held that the appeals fail, upheld the concurrent verdicts in favor of the first defendant, and disposed of the matter by dismissing the Second Appeals, while granting the plaintiff two months to vacate with conditions and safeguarding an affidavit-based breathing time.
This bail petition relates to the second accused in Crime No. 6 of 2020, registered at Panangad Police Station, Ernakulam, who seeks anticipatory bail in a case alleging rape of a 17-year-old victim and offences under IPC sections 376 and 506 r/w 34, along with Sections 3, 4, 6, 7, 11, 12, 16 and 17 of the Protection of Children from Sexual Offences Act, 2012. The prosecution contends that the first accused, with intent to commit penetrative sexual assault, recorded nude photographs of the victim and committed rape in April and May 2019; the petitioner is alleged to have aided the offence by failing to disclose it. The petitioner’s counsel asserts the case is false, arguing the petitioner had no knowledge of any rape and that the alleged relationship with the first accused and the victim is misunderstood; WhatsApp chats among the parties are relied upon, but are not conclusive proof of complicity and may reflect friendship rather than knowledge of the offence. The Public Prosecutor maintains custodial interrogation is essential given the seriousness of the allegations. The court notes a prior writ petition by the petitioner alleging investigation bias and material showing financial transactions between the first accused and the victim’s mother. While the chats show a connection, the court is of the view that there is no direct knowledge by the petitioner of the crime. Relying on the principle of limited custody from Sushila Aggarwal, the court allows custodial interrogation with conditions, and grants anticipatory bail subject to surrender, bonds, cooperation, non-tampering, and travel restrictions until further investigation.
