DR. BIPIN SHANTILAL PANCHAL vs STATE OF GUJRAT

The Supreme Court held that the provisions of Section 37 of the Narcotic Drugs and Psychotropic Substances Act, 1985 do not exclude the applicability of the proviso to sub-section (2) of Section 167 of the Code of Criminal Procedure. The Court clarified that the right to be released on bail under the said proviso is enforceable only until the filing of the charge-sheet, after which it does not survive. The appeal for bail was dismissed as the charge-sheet had already been filed, thus the appellant's right to bail under the earlier provision was no longer applicable.