Tunnaya Alias Gunapala v. Officer In Charge, Police Station, Galewela – sllr 1993 volume 1 page 061

In Tunnaya alias Gunapala (petitioner) v. Officer in Charge, Police Station, Galewela (respondent), the court considered whether the mere filing of a police investigation report under Section 116(1) of the Criminal Procedure Code, containing a specific allegation, constitutes the institution of criminal proceedings and thereby affects the grant of bail under Section 115(3). Upon review of the relevant statutory provisions (Sections 115, 116, 120, 136) and applicable case law, it was held that such a report does not automatically amount to the institution of proceedings, and the right to bail remains unless proper proceedings are initiated. The ruling affirmed the principle that the filing of a report alone is insufficient to preclude bail. The decision relied on a detailed interpretation o