#Article 22(2)

The Orissa High Court held that time taken for medical examination cannot be excluded from the 24-hour production mandate under Article 22(2) - only journey time is excludable. Consequently, the accused's detention beyond 25 hours vitiated the arrest and remand, entitling him to bail in an NDPS case involving 51 kg of ganja.

Delhi High Court ruled that five-day detention without magisterial authorization rendered the arrest illegal, nullifying Section 37 bail restrictions. The judgment reinforces procedural safeguards under Article 22(2) for foreign nationals in NDPS cases, setting a precedent for strict compliance in drug-related arrests.