General legal information, not advice on any individual case. Statutory exceptions, special laws and the facts of the matter must be considered. Publication date is not the date of the judgment or notification.
What the Supreme Court confirmed in July 2025
In Satender Kumar Antil v. CBI, 2025 INSC 909, decided on 16 July 2025, the Supreme Court rejected Haryana's request to modify its 21 January 2025 directions on notice service. WhatsApp and other electronic communication cannot be recognised as an alternative or substitute for service of a Section 41A CrPC or Section 35 BNSS notice in the prescribed statutory manner.
This is an earlier judgment, not a new October 2026 ruling. The January 2026 Antil decision subsequently cites and builds on the July ruling while explaining the safeguards against automatic arrest.
Police notices are different from court summons
The Court distinguished a court summons, a judicial act, from an investigating-agency appearance notice, an executive act. Rules authorising electronic court summons do not automatically authorise electronic service of a BNSS Section 35 notice.
The decision is not a ban on all electronic criminal procedure or on every police message. The judgment discusses other express electronic provisions, including BNSS Sections 94 and 193. The legal purpose of a communication and the provision authorising it must be identified.
Do not infer immunity from a defective message
A WhatsApp communication should not be treated as a substitute for the prescribed service solely because it contains a notice attachment. But a service defect is not, by itself, a conclusion that every independently justified arrest is invalid. Appearance-notice service, objective arrest necessity and written grounds of arrest raise distinct questions.
For a review of a police communication in Telangana or Andhra Pradesh, the relevant records include the original message, attachment, sender information and any paper notice or service record. They should be preserved as received. Whether the statutory requirements were met depends on the actual record, not only the app used to send a message.