The Supreme Court clarified that a High Court should not direct or suggest a particular manner of custodial interrogation while deciding an anticipatory bail application. The accused, a school principal and the president of the school's governing body, were alleged to have manipulated the principal's service records to alter his date of birth and extend his period of service. The Gujarat High Court had rejected anticipatory bail, observing that custodial interrogation was necessary to uncover the truth. The Supreme Court noted that the allegations were primarily document-based and that custodial interrogation was not necessary in the circumstances. It held that the decision regarding the appropriate method of interrogation must remain within the discretion of the investigating agency, subject to law. A High Court should not make sweeping observations suggesting that custodial interrogation of an accused or other persons is imperative, particularly when those persons are not parties before it. The judgment reinforces the limits of judicial observations, investigative independence, anticipatory bail and the protection of personal liberty under Article 21 of the Constitution.