Legal Analysis: Md. Ariz Hasnain @ Ariz Hasnain vs. State of Jharkhand

Citation: 2026 INSC 456
Court: Supreme Court of India
Bench: Justice Vikram Nath and Justice Sandeep Mehta (Judgment authored by Justice Mehta)
Date of Decision: April 30, 2026
Nature of Judgment: Criminal Appeal under Article 136 against High Court order dismissing petition challenging extension of time for filing chargesheet under UAPA.

Synopsis of the Judgment

The appellant was arrested under the UAPA. The 90‑day statutory period for filing chargesheet under Section 167(2) CrPC was to expire on 05.02.2024. On 02.02.2024, the trial court granted an extension of 25 days without issuing notice to the appellant or producing him before the court, and without any reasoned report from the Public Prosecutor. The appellant moved for default bail on 08.02.2024. The trial court rejected it, relying on the extension order. The High Court dismissed his petition, observing that the chargesheet had been filed within the extended period. The Supreme Court held that the extension order was illegal for violating principles of natural justice (no notice/opportunity to the accused) and for lack of application of mind. Consequently, the appellant’s indefeasible right to default bail crystallised on the expiry of 90 days. The appeal was allowed, and the appellant was ordered to be released on default bail.

1. Basic Information of the Judgment

Field Details Case Title Md. Ariz Hasnain @ Ariz Hasnain vs. State of Jharkhand Criminal Appeal No. Arising out of SLP(Crl.) No. 11860 of 2025 Bench Justice Vikram Nath and Justice Sandeep Mehta Date of Decision April 30, 2026 Citation 2026 INSC 456 Appeal From Order dated 21.02.2025 of Jharkhand High Court in Criminal M.P. No. 742 of 2024

2. Legal Framework

Laws/Provisions:

• Code of Criminal Procedure, 1973 (CrPC): Section 167(2) (default bail; time limit for completing investigation), Section 43‑D(2) of UAPA (special provision for extension)

• Unlawful Activities (Prevention) Act, 1967: Sections 18, 20, 38, 39

• Constitution of India, 1950: Article 21 (personal liberty)

Precedents Cited:

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