As per case facts, the appellant's prayer to extend anticipatory bail under Section 438 of the Code of Criminal Procedure was refused by the Calcutta High Court. A complaint had ... been lodged alleging various offenses under the Indian Penal Code against the appellant and five others, stating that the appellant, a previous President of ISKCON's Calcutta Branch, was suspended and committed offenses. The Chief Judicial Magistrate directed an investigation, leading to an FIR. The appellant appealed the High Court's refusal. The central legal question arose on the scope and duration of anticipatory bail under Section 438 CrPC, its distinction from regular bail under Section 439 CrPC, and whether a court can issue an interim order to restrain arrest while an anticipatory bail application is pending. Finally, the Supreme Court upheld the High Court's rejection, clarifying that Section 438 is for pre-arrest situations, and once arrested, the remedy shifts to regular bail under Sections 437 or 439, requiring 'custody'. The Court emphasized anticipatory bail should be of limited duration and not bypass regular courts. An interim order restraining arrest during a pending Section 438 application was deemed impermissible interference with investigation. The appellant was directed to surrender and then apply for regular bail for expeditious disposal.