APHC010232492026 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3521] MONDAY, THE TWENTY SECOND DAY OF JUNE TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE DR JUSTICE Y. LAKSHMANA RAO CRIMINAL PETITION NO: 3652/2026 Between: 1. SMT DAKKA NANDINI, D/O DAKKA SUBRAMANYAM, AGED 29 YEARSR/O DODDIVARIPALLI VILLAGE,H/O GONGIVARIPALLI VILLAGE POST,SODUM MANDAL, ANNAMAYYA DISTRICT.PETITIONER/ACCUSED ...PETITIONER/ACCUSED AND 1. THE STATE OF ANDHRA PRADESH, ,Rep.by Public Prosecutor,High 5ourt of Andhra Pradesh throughKadiri Town PS, Ananthapuramu ...RESPONDENT/COMPLAINANT Counsel for the Petitioner/accused: 1. GANTA EDIGA RAKESH GOUD Counsel for the Respondent/complainant: 1. PUBLIC PROSECUTOR The Court made the following: 2 ORDER: Criminal Petition has been filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 20231 by the Petitioner/Accused, for granting of pre-arrest bail in connection with Crime No.66 of 2026 of Kadiri Town Police Station, Ananthapuramu, registered for the alleged offences punishable under Section 194 of ‘the BNSS’. 2. Heard the learned counsel for the Petitioner and the learned Assistant Public Prosecutor. Perused the record. 3. On perusal of the record, it appears that the husband of the Petitioner has alleged that the Petitioner caused the death of their child. The learned Assistant Public Prosecutor submits that the Investigating Officer has not yet been able to ascertain who is the actual culprit. The investigation is presently in a grey area, and remains inconclusive as to who caused the death of the son of the Petitioner and the de-facto complainant. However, the postmortem report indicates that the death of the child was not due to natural causes, but on account of a fracture of the hyoid bone. Since the investigation is at its initial stage, and the police have not gathered sufficient material or clarity to identify the accused, the filing of an application for anticipatory bail at this juncture is premature and not maintainable. 4. The Hon'ble Apex Court in Bhadresh Bipinbhai Sheth v. State of Gujarat2, reiterated the principles governing the grant of anticipatory bail. 1 ‘the BNSS’ 2 (2016) 1 SCC 152 3 5. The Hon'ble Apex Court in Salauddin Abdulsamad Shaikh v. State of Maharashtra3, held that when there is no real apprehension of arrest, there is no necessity for granting anticipatory bail. 6. Further, the Hon'ble Apex Court in Adri Dharan Das v. State of W.B.,4, held that pre-arrest bail cannot be sought as a matter of right and that a genuine apprehension of arrest must be established. 7. Having regard to the facts and circumstances of the case, and since the Investigating Officer has not yet finalized the investigation to establish the guilt of the petitioner in causing the death of her child, there appears to be no real apprehension of arrest at present. Consequently, the petitioner is not entitled to anticipatory bail. Accordingly, the request for grant of pre-arrest bail at this juncture is found neither convincing nor reasonable, and the Criminal Petition is liable to be dismissed. 8. In the result, the Criminal Petition is dismissed. _________________________ DR. Y. LAKSHMANA RAO, J Date: 22.06.2026 PRA 3 (1996) 1 SCC 667 4 (2005) 4 SCC 303 4 113 THE HONOURABLE DR JUSTICE Y. LAKSHMANA RAO CRIMINAL PETITION NO: 3652 of 2026 22.06.2026 PRA