In Sanjay Kumar Gupta v. State of U.P. & Ors., the Supreme Court held that a High Court cannot grant pre-arrest or anticipatory bail while refusing to quash an FIR, as such orders are self-contradictory and risk prejudicing investigations. The case arose from writ petitions under Article 226 where the Allahabad High Court denied quashing of FIRs under the Bharatiya Nyaya Sanhita, 2023, yet simultaneously granted the accused blanket protection from arrest until filing of the charge sheet. The Supreme Court emphasized that powers under Article 226 are not a substitute for Section 438 CrPC, and anticipatory bail relief in writ petitions should be exceptional, not routine. Since pre-arrest relief is available under statutory provisions, accused must first approach the competent Sessions Court. Upholding the principle of separation of remedies, the Court clarified that quashing and anticipatory bail applications are distinct. The High Court’s orders were set aside, and the matter remanded for fresh consideration on merits, balancing the rights of the accused with the integrity of investigation and public interest.