INTRODUCTION  The Supreme Court of India has in its recent landmark judgment in Satender Kumar Antil[1] laid down guidelines on the grant of bail to an accused and while doing so, it has reiterated aspects of personal liberty and constitutional guarantees available to an accused under criminal jurisprudence. The Court observed that while its discussion and findings are meant to operate as guidelines, each case pertaining to a bail application is to be decided on its own merits.[2] This article seeks to analyse these guidelines and evaluate their consequences and operation in practice. GUIDELINES WITH RESPECT TO DIFFERENT CATEGORIES OF OFFENCES  The judgment has categorised offences into four different categories and has observed that these guidelines would operate upon the satisfaction of two conditions i.e., (a) that the accused was not arrested during the investigation and that (b) the accused co-operated throughout in the investigation including appearing before the Investigating Officer (“IO”) whenever called. These four categories are:[3] A. Offences punishable with imprisonment of 7 years or less not falling in category B & D. B. Offences punishable with death, imprisonment for life, or imprisonment for more than 7 years.  C. Offences punishable under Special Acts containing stringent provisions for bail like NDPS (s.37), PMLA (s.45), UAPA (s.43D(5), Companies Act, 212(6), etc. D. Economic Offences not covered by Special Acts. With respect to Category A, the Guidelines appear to be comparatively lenient to the Accused, given the lesser gravity of the offences involved. Here, after filing of the charge sheet or the complaint taking cognizance, ordinary summons must be issued at the first instance including an appearance through lawyer. However, if the accused does not appear despite service of summons, then a Bailable Warrant for physical appearance may be issued. Again, if the accused fails to appear despite issuance of bailable warrant, a non-bailable warrant will be issued. Such non-bailable warrant may be converted by the Magistrate into a bailable warrant/summons without insisting on physical appearance of the accused, if the accused moves an application before execution of the non-bailable warrant on an undertaking to appear physically on the next date of hearing. Once an appearance is made in Court, bail applications may be decided without taking such accused into custody or by granting interim bail till the bail application is decided. With respect to Categories B and D, the bail application will be decided on merits on appearance of the accused in Court pursuant to process being issued. Furthermore, as far as economic offences are concerned, the Supreme Court observed that to determine whether or not to grant bail, two aspects need to be considered i.e., seriousness of the charge and severity of the punishment. In the context of white-collar crimes, the aforementioned factors are usually considered to decide on bail applications. Finally, with respect to Category C, the guidelines are the same as Categories B and D with the additional condition of compliance with strict bail provisions under Section 37 of the Narcotics Drugs and Psychotropic Substances Act, 1985; Section 45 of the Prevention of Money Laundering Act, 2002; Section 212(6) of the Companies Act, 2013; Section 43(d)(5) of the Unlawful Activities (Prevention) Act, 1967 and the provisions under the Protection of Children from Sexual Offences Act, 2012. OTHER BROADER GUIDELINES AS REGARDS THE GRANT OF BAIL In addition to the abovementioned guidelines, the Supreme Court also conducted a broader analysis of provisions of the Code of Criminal Procedure, 1973 (“CrPC”) and laid down certain other guidelines on the grant of bail (“CrPC”) as analysed hereinunder: i. Section 41/41A Notice and bail on its non-compliance  As regards Section 41 of the CrPC, the Supreme Court has significantly observed that even for a cognizable offence, an arrest of the accused is not mandatory and that an arrest in offences punishable with imprisonment below seven years or extending to seven years can only be made if the IO is satisfied that there is a reason to believe that the accused committed the offence and that there is necessity for such an arrest. Pertinently, Section 41 mandates the IO to record the reasons while choosing to arrest/or not choosing to arrest. However, this is not required if the offence alleged involves imprisonment for more than seven years. The Supreme Court relied on its judgment in Arnesh Kumar wherein it was held:[4] “In pith and core, the police officer before arrest must put a question to himself, why arrest? Is it really required? What purpose it will serve? What object will it serve? It is only after these questions are addressed that the power of arrest needs to be exercised…Apart from this, the police officer has to be satisfied further that the arrest is necessary for one or more purposes envisaged by sub-clauses (a) to (e) of clause (1) of Section 41 CrPC”. Furthermore, the Court also held that in addition to the reason to believe, the satisfaction for the need to arrest shall also be present.[5] As regards Section 41A CrPC, it requires the IO to issue a notice to the person against whom a reasonable complaint has been made, or credible information has been received or a reasonable suspicion exists that he has committed a cognizable offence, and arrest is not required under Section 41(1). In this regard, the Court held that Sections 41 and 41A are facets of Article 21 of the Constitution and that any arrest in non-compliance of Section 41/41A CrPC would entitle the accused to bail. Further, the Court mandated all States and Union Territories to facilitate standing orders to comply with Section 41/41A and observed that the directions laid down in the Arnesh Kumar judgment had not been followed.[6]These guidelines clearly underline the intent of the Supreme Court to ensure procedural safeguards are complied with and any non-compliance is sufficient to grant bail to the accused. ii. Default bail under Section 167(2) CrPC Section 167 of the CrPC pertains to the procedure when an investigation cannot be completed in twenty-four hours and also provides the maximum period of time to complete an investigation i.e.,