Introduction 

This case reconsidered the general concept that police remand cannot be granted beyond 15 days period. 

Facts 

• The Central Bureau of Investigation registered cases under Section 120B, read with Section 409 of the Indian Penal Code (IPC), and the Prevention of Corruption Act against officials of Eastern Coalfield Limited, CISF, and railways. 
• The defendant was arrested and remanded to 7 days of police custody. 
• The defendant was admitted to the hospital, preventing the CBI from conducting the investigation, and the Special Court granted him interim bail. 
• The Special Court later canceled the bail order and remanded the defendant to judicial custody. 
• During judicial custody, the defendant was admitted to the hospital for most of the time. 
• The defendant then filed an application before the Special Court under Section 167(2) of the Code of Criminal Procedure, on the grounds of non-filing of the charge sheet/report within the period of 90 days from the date of arrest. 
• The Special Court rejected the application. 
• The defendant challenged the order of the Special Court before the Calcutta High Court, which allowed the application and directed his release on bail. 
• The CBI filed an appeal before the Supreme Court challenging the decision of the High Court. 

Issue Involved  

• Whether police custody can be granted even after expiry of 15 days period from the date of arrest?  

Observations 

• The Supreme Court observed that the defendant misused the liberty given to him and was uncooperative, which prevented the CBI from conducting their investigation. 
• The Supreme Court also stated that the principle established in Central Bureau of Investigation v. Anupam J. Kulkarni (1992) should be reconsidered and redetermined. 

Conclusion 

The Supreme Court allowed the present appeal and ordered the defendant's police remand for four days for interrogation by the CBI.