The Uttarakhand High Court held that Article 22(1) does not require a separate written document for “grounds of arrest” if the arrest memo itself clearly conveys essential allegations. The petitioner argued that failure to provide written grounds made the arrest illegal. The Court clarified that the purpose of Article 22(1) is to ensure that the accused understands why he is being arrested and can defend himself. It distinguished between “grounds of arrest” (basic factual allegations) and “reasons for arrest” (justification), holding that only the former must be communicated. Adopting a functional approach, the Court applied the “meaningful communication” test and held that substantial compliance is sufficient. Since the arrest memo contained offences and factual details, the accused was adequately informed. Accordingly, the arrest and remand were upheld as valid.