Vihaan Kumar v. State of Haryana, 2025: Case Summary

Court: Supreme Court of India

Citation: Crl.A. No. 621/2025

Jurisdiction: Constitutional (Writ) Jurisdiction of the Supreme Court under Article 32

Date of The Judgement: 7th February 2025

Bench: Justice Abhay S. Oka and Justice N. Kotiswar Singh

Petitioner: VIHAAN KUMAR

Respondent: STATE OF HARYANA & ANR.

INTRODUCTION:

The judgment delivered by the Supreme Court in Vihaan Kumar v. State of Haryana & Anr. reaffirms vital constitutional protections afforded to individuals under arrest and detention. The Constitution, through Articles 21 and 22, places procedural safeguards around arrest and detention to ensure that the coercive power of the State is not exercised arbitrarily. Despite these guarantees, violations in the form of unlawful arrests and custodial indignities persist.

 In this landmark judgment, the Supreme Court reaffirmed that the right to be informed of the grounds of arrest is not a procedural nicety but a substantive constitutional mandate and underscores the necessity of ensuring due process in criminal proceedings and reiterates the importance of treating every detainee with dignity, regardless of the nature of the accusations.

FACTS OF THE CASE:

• Vihaan Kumar was implicated in FIR No. 121 of 2023 dated 25 March 2023, alleging that the petitioner, Vihaan Kumar, had committed serious financial and document-related offences registered under Sections 409, 420, 467, 468, 471 read with 120-B IPC. He was arrested on 10 June 2024 in Gurugram, Haryana.
• The appellant asserted that he was not informed of the grounds of his arrest, either orally or in writing and he was arrested around 10:30 a.m. but produced before the Magistrate only on 11 June 2024 at 3:30 p.m. allegedly violating Article 22(2) (mandating production before a magistrate within 24 hours) and Section 57 CrPC. The police later claimed, without convincing evidence, that the arrest occurred at 6:00 p.m. instead of 10:30 a.m., to cover up the delay.
• During custody, he was hospitalised at PGIMS, Rohtak, At the hospital, he was handcuffed and chained to the hospital bed, despite there being no risk of flight or violence. These restraints were applied without any prior judicial approval, in violation of established legal standards regarding custodial treatment.
• The State contended variously that the wife of the accused had been informed, and that entries in case diaries, arrest memos, or remand reports fulfilled legal requirements.
• The Punjab and Haryana High Court on 30 August 2024 upheld the arrest, finding no constitutional violation. This prompted the appellant’s challenge in the Supreme Court.
• Aggrieved by the violation of his fundamental rights, the petitioner approached the Supreme Court under Article 32 of the Constitution, alleging infringement of Articles 21 and 22(1), seeking redress for the illegalities and inhuman treatment suffered during his arrest and custody.

KEY ISSUES IN CASE:

• Whether the Appellant’s arrest was rendered illegal due to non-compliance with Article 22(1) of the Constitution (failure to communicate grounds of arrest).
• Whether the Appellant’s treatment (handcuffing and chaining to a hospital bed) violated his fundamental right to dignity under Article 21.
• Whether subsequent legal processes (remand, chargesheet) can validate an arrest vitiated by constitutional violations.

ARGUMENT OF BOTH PARTIES:

PETITIONER’S ARGUMENT:

1. The petitioner submitted that the arresting officers had failed to inform him of the grounds of arrest, as required under Article 22(1) of the Constitution and Section 50 of the Code of Criminal Procedure, 1973 (CrPC).
2. The petition noted that the only person informed was his wife, which the petitioner argued does not satisfy the mandatory requirement of informing the arrested person himself.
3. Cited Pankaj Bansal v. Union of India and Prabir Purkayastha v. State (NCT of Delhi), submitted that on the failure of the 1st respondent to comply with the mandate of Article 22(1) and Section 50 of CrPC, the arrest of the appellant is rendered illegal.
4. The petitioner also contended a violation of Article 22(2) of the Constitution (and Section 57 CrPC) namely, that he was not produced before a magistrate within 24 hours of his arrest and that the remand memo and arrest record did not clearly mention the precise time of arrest, leading to ambiguity and violation of the constitutional safeguard.
5. Further, the petitioner argued a breach of his fundamental right to dignity under Article 21 of the Constitution since while in custody and hospitalised (at PGIMS Rohtak) he was handcuffed and chained to the hospital bed without any strong reasons, and without prior judicial approval.

RESPONDENT’S ARGUMENT:

1. The State contended that the police had complied with legal requirements by documenting the arrest in official records and by informing the petitioner’s spouse. It argued that these actions satisfied the obligation under Article 22(1).
2. To justify the timeline, the State submitted that the arrest occurred at 6:00 p.m. on 10 June and that Vihaan was produced before the magistrate within 24 hours. Regarding the handcuffing, the State attempted to justify it as a routine security measure due to the accused’s status and the seriousness of the charges.
3. The State contended the petitioner actually remained in custody after proper remand/charge-sheet and thus seeking immediate release would undermine the process already underway.

JUDGMENT:

• The Court held that the arrest was illegal and void ab initio because the arresting officers failed to inform the petitioner of the grounds of arrest, which is a mandatory constitutional requirement under Article 22(1) and a statutory duty under Section 50(1) CrPC.
• It held that a defective or unconstitutional arrest cannot be validated by later judicial remand or by filing of a charge sheet.
• The Court found the handcuffing and chaining of the petitioner while he was hospitalized to be a gross violation of Article 21.

REASONING OF JUDGMENT:

Violation of Article 22(1): Failure to Communicate Grounds of Arrest
The Supreme Court held that Article 22(1) mandates that an arrested person be informed of the grounds of arrest “as soon as may be,” ensuring the ability to challenge detention and seek legal remedies. The Court referred to Pankaj Bansal v. Union of India 2023 and Prabir Purkayastha v. State (NCT of Delhi) 2024 and held that communication of grounds must be meaningful and effective, preferably in writing, to avoid disputes. While Article 22(1) does not explicitly require written communication, the Court ruled that vague assertions or oral claims by police are insufficient.

The State claimed the Appellant’s wife was informed, which the Supreme Court dismissed as irrelevant to constitutional compliance. The State’s reliance on a case diary entry (recording communication of grounds at 6:10 PM) was rejected by the Court as an “afterthought” due to the absence of contemporaneous documentation of the actual grounds. The Court reasoned that the burden to prove compliance lies on the State, and mere diary entries without detailing the grounds were deemed inadequate. The Court said that subsequent procedural compliance cannot retrospectively cure a constitutional defect at the time of arrest.

 Violation of Article 21: Handcuffing and Chaining to Hospital Bed
The Supreme Court condemned the Appellant’s treatment as a gross violation of dignity under Article 21. The Court found the handcuffing and chaining to a hospital bed without justification shocking and unconstitutional.

Relying on earlier precedents like –

• Prem Shankar Shukla v. Delhi Administration 1980, and Citizens for Democracy v. State of Assam 1995,
  the Court reiterated that handcuffing is permitted only in exceptional circumstances with prior judicial approval and recorded reasons.

Justice Singh in his concurring opinion, reinforced Justice Oka’s conclusions while elaborating on the constitutional and statutory imperatives underpinning the communication of grounds of arrest. He reasoned that the mandate of Article 22(1) requiring arrested persons to be informed of the grounds of arrest is not merely procedural but a fundamental safeguard to protect liberty under Article 21. Justice Singh ruled that written communication of grounds is essential to ensure the arrestee can meaningfully challenge detention and seek legal remedies.

IMPACT:

The Supreme Court’s decision in Vihaan Kumar v. State of Haryana is more than a correction of individual injustice it sets a strong precedent for constitutional governance and institutional accountability. The judgment underscores that procedural safeguards are not mere formalities but essential components of personal liberty. The ruling reinforces that law enforcement agencies must treat the rights of the accused with utmost seriousness, especially at the stage of arrest. The insistence on direct and timely communication of arrest grounds ensures that individuals are not detained arbitrarily or without recourse to legal remedies. This pushes police departments across states to adopt more transparent and standardized procedures.

By declaring that the handcuffing or chaining of an accused without judicial sanction violates human dignity, the judgment has reinforced the principle that procedural fairness is a cornerstone of personal liberty. It sets a strong precedent ensuring that law enforcement officers must exercise arrest powers responsibly and within constitutional bounds.

CONCLUSION:

In conclusion, the Vihaan Kumar v. State of Haryana judgment stands as a significant milestone in protecting individual liberty and upholding the constitutional mandate of fairness, dignity, and accountability in the criminal justice system. The Supreme Court’s firm stance that an arrest made without informing the accused of its grounds is unconstitutional, and that inhuman treatment like handcuffing or chaining violates Article 21, reinforces the rule of law and the sanctity of human rights. The decision not only rectifies the injustice faced by the petitioner but also lays down vital safeguards for future cases, ensuring that police powers are exercised with responsibility and constitutional sensitivity. It thus serves as a strong reminder that the protection of liberty is the foundation of justice in a democratic society.

REFRENCES:

1. Vihaan Kumar v. State of Haryana, 2025 INSC 162, Crim. App. No. 621 of 2025
2. Pankaj Bansal v. Union of India 2023 INSC 866
3. Prabir Purkayastha v. State (NCT of Delhi) 2024 INSC 414
4. Prem Shankar Shukla v. Delhi Administration (1980 3 SCC 526)
5. Citizens for Democracy v. State of Assam (1995 3 SCC 743)
6. The Amikus Qriae, Vihaan Kumar v. State of Haryana & Anr., 2025 INSC 162, (Feb. 7, 2025), https://theamikusqriae.com/vihaan-kumar-v-state-of-haryana-anr-2025-insc-162/
7. Aastha Rathi, Case Comment: Vihaan Kumar v. State of Haryana, 4 J. L. R. & J. Stud. Iss. 4 (Sept. 2025), https://jlrjs.com/wp-content/uploads/2025/09/202.-Aastha-Rathi.pdf.
8. Supreme Court of India, Judgment Diary No. 4329/2024, (Feb. 7, 2025), https://www.sci.gov.in/view-pdf/?diary_no=432932024&type=j&order_date=2025-02-07&from=latest_judgements_order