In Mihir Rajesh Shah vs. State of Maharashtra and Another, the Supreme Court examined whether furnishing written grounds of arrest is mandatory under Article 22(1) of the Constitution and procedural law. The appellant challenged his arrest in a hit-and-run case, arguing that the police failed to provide written grounds of arrest, thereby violating his fundamental rights. Although the Bombay High Court noted the lapse, it upheld the arrest, prompting an appeal. The Supreme Court held that informing the grounds of arrest is a mandatory constitutional safeguard applicable to all arrests, including those under general criminal law now governed by the BNSS, 2023. To make this right meaningful, the Court ruled that grounds of arrest must be furnished in writing and in a language understood by the arrestee. Oral communication alone was held insufficient, except in exceptional “in-the-act” situations. Even then, written grounds must be supplied at least two hours before production before a magistrate. Failure to comply renders the arrest and subsequent remand illegal, entitling the accused to release.