Supreme Court Explains Bail Jurisdiction: High Courts Cannot Issue Statewide Administrative Directions While Deciding Bail

Case Name: Rambalak v. State of U.P.

Citation: 2026 INSC 511

Date of Judgment/Order: 19 May 2026

Bench: Justice Sanjay Karol and Justice Prasanna B. Varale

Held: The Supreme Court held that while exercising bail jurisdiction under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, the High Court or Court of Session is confined to deciding whether the accused should be released on bail, whether bail conditions should be modified, or whether a person already released on bail should be taken back into custody. The Court clarified that even though a High Court is a constitutional court, it cannot use its statutory bail jurisdiction to issue broad, general or statewide administrative directions unrelated to the grant or refusal of bail. The Court reiterated that constitutional powers and statutory powers are distinct, and constitutional status cannot be used to enlarge the scope of a statutory jurisdiction beyond what the statute permits.

Summary: The appeal arose from the rejection of the appellant’s second bail application by the Allahabad High Court in a criminal case under Sections 419, 420, 467, 468 and 471 IPC. While dismissing bail, the High Court reiterated earlier directions issued in other bail matters requiring trial courts and State authorities to follow detailed mechanisms for service of summons, execution of coercive processes and departmental accountability of police and administrative officers. The Supreme Court had already released the appellant on bail by interim order dated 26.11.2025 and thereafter examined the larger issue whether such directions could be issued while exercising bail jurisdiction. Referring to Section 483 BNSS and its recent decision in State of U.P. v. Anurudh, the Court held that the power under bail jurisdiction is statutory and limited. It explained that although the High Court possesses constitutional powers, such powers cannot overshadow or expand the narrower statutory power being exercised in a bail proceeding. Therefore, directions relating to systemic reforms in summons service and police accountability could not be treated as valid directions issued in a bail order under Section 483 BNSS.

Decision: The Supreme Court allowed the appeal and set aside the impugned judgment to the extent it directed compliance with broad administrative directions earlier issued in bail orders. However, in the interest of justice, the Court clarified that steps already taken by State authorities pursuant to those directions would remain unaffected and could continue independently of the High Court’s bail orders, with liberty to the State to modify them in accordance with law. The Court confirmed its interim order dated 26.11.2025 granting bail to the appellant, clarified that it had made no comment on the grant or denial of bail in the earlier High Court orders, and disposed of all pending applications.