The petitioner, Kamayaka Reeju (Accused No. 3), sought regular bail before the Kerala High Court in connection with Crime No. 281/2026 of Chevayoor Police Station, Kozhikode, where she was allegedly found in possession of 108.28 grams of MDMA on 21.04.2026, an offence punishable under Section 22(c) of the NDPS Act. The petitioner argued that her arrest was illegal as the grounds of arrest were not properly communicated to her, violating Article 22(1) of the Constitution of India and Section 47 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS). The Court, after reviewing the case diary, found that while separate grounds of arrest were communicated to the applicant and her relatives, the quantity of contraband seized was not mentioned, which is mandatory in NDPS cases as it determines whether the offence is bailable or non-bailable and the category of the quantity involved. Relying on a series of Supreme Court precedents including Pankaj Bansal, Prabir Purkayastha, Vihaan Kumar, and Mihir Rajesh Shah, as well as Kerala High Court decisions, the Court held that the requirements of Article 22(1) of the Constitution and Section 47 of BNSS were not satisfied, rendering the arrest and subsequent remand illegal. Accordingly, the bail application was allowed.