Vihaan Kumar v. State of Haryana: Supreme Court Reinforces Arrest Rights Under Article 22

Introduction

In Vihaan Kumar v. The State of Haryana (2025 INSC 162), the Supreme Court delivered a landmark judgment reinforcing the constitutional safeguards surrounding arrest, particularly the mandatory communication of grounds of arrest.

Facts

The appellant was arrested for offences under Sections 409, 420, 467, 468, and 471 read with Section 120-B IPC. He alleged that grounds of arrest were not communicated and was later found handcuffed and chained to a hospital bed.

Key Holdings

Justice Abhay S. Oka held that:

• Article 22(1) Mandate: Communication must be meaningful and effective, preferably in writing
• Burden of Proof: The State must prove compliance; mere diary entries without actual grounds are inadequate
• No Validation: Constitutional violations at arrest cannot be cured by subsequent chargesheet filing or remand orders

On Dignity and Handcuffing

The Court condemned the handcuffing and chaining to hospital bed as a gross violation of dignity under Article 21, directing the State to issue guidelines preventing such practices.

Practical Implications

This judgment mandates police to document grounds of arrest contemporaneously and communicate them effectively to the arrested person, strengthening individual liberty protections.