SUSHILA AGARWAL & ORS. VS. STATE (NCT OF DELHI) & ANR.
Life or duration of an anticipatory bail order does not normally end at the time and stage when the accused is summoned by the Court, or when charges are framed, but can continue till the end of the trial. Again, if there are any special or peculiar features necessitating the court to limit the tenure of anticipatory bail, it can do so.
Consistent with the judgment of Shri Gurbaksh Singh Sibbia & ors. v. State of Punjab, when a person complains of apprehension of arrest and approaches for order, the application should be based on concrete facts relatable to one or other specific offence. it is not essential thatan application should be moved only after an FIR is filed; it can be moved earlier, so long as the facts are clear and there is reasonable basis for apprehending arrest.