Kasireddy Upender Reddy v. State of Andhra Pradesh & Ors., 2025 LiveLaw (SC) 628

In a significant ruling dated May 26, 2025, the Supreme Court of India delivered a landmark judgment in the case Kasireddy Upender Reddy v. State of Andhra Pradesh & Ors. [2025 LiveLaw (SC) 628]. A bench comprising Justices J.B. Pardiwala and R. Mahadevan settled a crucial legal question concerning the procedural safeguards surrounding arrest, specifically in the context of arrests made under judicial warrants.

The Court held that when an arrest is carried out pursuant to a warrant issued by a competent court, there is no separate requirement to inform the arrested person of the grounds of arrest, provided the warrant is shown and read over to them. According to the Court, the warrant itself constitutes the grounds of arrest, and the constitutional mandate under Article 22(1) stands fulfilled in such a scenario.

This ruling not only reaffirms the legal status of arrest warrants as sufficient notice of grounds of arrest but also provides clarity on the scope and application of fundamental rights related to personal liberty and procedural fairness.
Background of the Case:

• The petitioner, Kasireddy Upender Reddy, was arrested by the Andhra Pradesh Police pursuant to a warrant issued by a Magistrate.
• He challenged the legality of his arrest, contending he was not informed separately of the grounds for his arrest, violating Article 22(1) of the Constitution.
• The respondents, including the State of Andhra Pradesh, argued the warrant was shown and read out, fulfilling the constitutional requirement.
   

• Legal Issue:
  • Whether a person arrested pursuant to a court-issued warrant must be separately informed of the grounds for arrest under Article 22(1), or whether the warrant itself suffices?
     
• Relevant Constitutional Provision:
  • Article 22(1) of the Constitution of India: "No person who is arrested shall be detained in custody without being informed, as soon as may be, of the grounds for such arrest nor shall he be denied the right to consult, and to be defended by, a legal practitioner of his choice."
  • This ensures that an arrestee knows the reasons for their detention, enabling legal challenge or recourse.
     
• Observations of the Court:
  • Justice J.B. Pardiwala emphasized the context of arrest: warrant vs. non-warrant arrests.
  • The Court stated that in warrantless arrests, informing the grounds is more crucial due to the lack of prior judicial scrutiny.
  • For warrant-based arrests, the judicial order inherently contains the grounds, and reading it out satisfies Article 22(1).
  • The Court stated the requirement is not a ritual but must ensure the arrestee understands the reason for the arrest.
     
• Precedent and Doctrinal Basis:
  • Refers to Joginder Kumar v. State of U.P., (1994) 4 SCC 260 and DK Basu v. State of West Bengal, (1997) 1 SCC 416 — both emphasizing procedural safeguards in warrantless arrests.
  • Distinguished from those cases as the present matter involves a warrant-based arrest.
  • Also referred to Kartar Singh v. State of Punjab, (1994) 3 SCC 569 — noting that the form of communication depends on the context of arrest.
     
• Implications of the Judgment:
  • Clarifies that a judicial warrant, when read and explained, fulfills Article 22(1) obligations.
  • Reduces procedural burden on authorities in warrant-based arrests.
  • Ensures arrested persons still understand the reason for arrest, protecting constitutional rights.
  • Reduces risk of litigation based on technical arrest-related procedural lapses.
  • Aligns Article 22(1) interpretation with practical realities while upholding judicial scrutiny.

Criticism and Concerns:
While the ruling has brought clarity, some legal commentators may raise concerns about the potential for misuse. If arresting officers become complacent and do not properly explain the contents of the warrant or ensure that the arrested individual understands it, the fundamental right under Article 22(1) may be rendered illusory in practice.

Therefore, while the judgment offers a judicially efficient resolution to a recurring procedural question, its real-world efficacy will depend on strict compliance with the mandate of reading and explaining the warrant meaningfully, rather than as a perfunctory formality.

Conclusion:
The Supreme Court's decision in Kasireddy Upender Reddy v. State of Andhra Pradesh & Ors. [2025 LiveLaw (SC) 628] reinforces the principle that the legal process leading to an arrest matters significantly in determining the procedural obligations under Article 22(1). Where an arrest is made pursuant to a court-issued warrant, the requirement of informing the arrestee of the grounds for arrest is fulfilled by the warrant itself, provided it is properly communicated.

This landmark ruling provides clarity for law enforcement authorities and ensures a balanced approach between safeguarding individual liberties and facilitating efficient legal processes. Going forward, this judgment will serve as an important precedent in interpreting constitutional guarantees within the framework of criminal procedure in India.

Written By: Md.Imran Wahab, IPS, IGP, Provisioning, West Bengal
Email: imranwahab216@gmail.com, Ph no: 9836576565