The High Court of Kerala, Ernakulam, held that an arrest is illegal if the grounds of arrest are not communicated to the arrestee as soon as possible, reaffirming constitutional safeguards under Article 22(1). In Vishnu N P & Ors. v. State of Kerala & Anr., multiple NDPS bail applications were heard together, raising common issues on non-compliance with Articles 21 and 22 of the Constitution and Sections 47–48 of the Bharatiya Nagarik Suraksha Sanhita, 2023. The Court held that grounds of arrest must ordinarily be communicated in writing; mere oral intimation is insufficient. While oral communication may be permissible in exceptional situations, written grounds must be supplied at least two hours before production before the Magistrate to enable effective legal consultation. The Court clarified that an arrest memo is distinct from grounds of arrest, as the latter must contain specific allegations and reasons for arrest. Once non-communication is alleged, the burden lies on the police to prove compliance through contemporaneous records. Failure renders the arrest illegal and void, and subsequent filing of a chargesheet does not cure the defect. Applying these principles, bail was granted in three cases due to violation of Article 22(1), while one application was rejected where proper compliance was proved.