Facts: The petitioner, who was facing multiple cases, challenged the practice of seeking continuous remands to elongate custody. Despite the quashing of an FIR in one case, the report was revived when the petitioner was arrested for another case, prompting a request for anticipatory bail.

Issue: Can an accused already in custody for one case seek anticipatory bail for another case?

Observation: The Chief Justice of India expressed the view that anticipatory bail cannot be denied solely because the accused is in custody for another case. Under Section 41(b)(ii)(b) of the CrPC, the investigating authority can seek custody for proper investigation, but this does not preclude the possibility of anticipatory bail. Section 438 CrPC should address concerns about potential arbitrary arrests, recognizing the accused's fear of arrest regardless of existing constraints on the arresting officer's power.