As per case facts... The State of Haryana filed an application seeking modification of a previous order that had directed all States and Union Territories to issue Standing Orders requiring ... police to use only the modes of service for Section 41-A CrPC/Section 35 BNSS notices as prescribed by law, excluding electronic communication as an alternative or substitute. Haryana argued that the BNSS, 2023, now permits electronic service for summons and notice, and the prohibition wastes state resources and allows evasion of service. The question arose whether a notice issued by the Investigating Agency under Section 35 of the BNSS, 2023, can be validly served through electronic communication such as WhatsApp, similar to court-issued summons under the new law. Finally, the Supreme Court dismissed the application, affirming its earlier order. The Court reasoned that the BNSS, 2023, consciously omitted the service of a Section 35 notice from the procedures permissible through electronic communication under Section 530. A Section 35 notice, which could lead to arrest and deprivation of liberty upon non-compliance (Section 35(6)), carries a substantive element and cannot be equated with a Court-issued summons to a witness, which is a judicial act and does not have the same immediate bearing on liberty. Thus, electronic service is not a valid mode for Section 35 notices, as its conscious omission reflects the legislative intent to safeguard the fundamental right to life and personal liberty under Article 21.