Rekha Patel vs Pankaj Verma And Ors

The Supreme Court held that the High Court's order allowing anticipatory bail under Section 438 Cr.P.C. was inappropriate as Section 438 does not apply in the State of Uttar Pradesh. The Court emphasized that once an accused surrenders and their bail application is rejected, the protection granted by the High Court cannot be maintained, referencing the precedent set in Adri Dharan Das v. State of West Bengal (2005). Consequently, the appeal was allowed, and the High Court's order was set aside.