Smt. Shalini Bhateja & Anr. v. The State of U.P. & Ors.
Background
Three parallel proceedings arose from the same cheating-refund dispute; two had effectively died out (stayed or withdrawn), leaving only one FIR with a completed chargesheet, over which the petitioners still faced arrest risk.
Decision Breakdown
Without disturbing the High Court's refusal to quash the surviving FIR, the Supreme Court closed the two dead proceedings and directed bail be granted on appearance before the trial court, since a chargesheet had already been filed and custody wasn't necessary.
Lesson Learnt
Even when a High Court declines to quash an FIR, the Supreme Court can still prevent unnecessary custody by directing bail on appearance, especially where parallel proceedings show the dispute is largely resolved.