In a significant ruling dated 27 june 2025, the Bombay High Court held that pre-arrest medical examination cannot be used to justify detention beyond 24 hours, as mandated under Article 22(2) of the Constitution and Section 57 of the CrPC. The petitioner, a 58-year-old retiree, was taken into custody on 25 October 2024 at 1:00 PM in a cheating case involving over ₹3.37 crore. He was formally arrested after 32 hours and produced before the magistrate after 47 hours and 20 minutes, violating the 24-hour rule. The Court clarified that arrest begins the moment liberty is restrained, not when it's formally recorded. Only travel time to court can be excluded from the 24-hour window—not medical exam duration. Declaring the arrest illegal, the Court ordered the petitioner's release on PR bond of ₹1,00,000, asserting that constitutional safeguards cannot be bypassed through procedural delays.