Shri V. R. Kingaonkar in his article. 'Anticipatory bail is a misnomer', appearing in the January issue of the Criminal Law Journal, 1982, has made certain observations about the power of magistrates in remanding accused u/s 209 (b) Cr. P. C., which require reconsideration in the light of the decisions of the Supreme Court in AIR 1977 SC 366: 1977 Cri LJ 225, Balchand's case, AIR 1980 SC 1632: 1980 Cri LJ 1125 and Gurbaksh's case. It is true that in the Balchand's case, Supreme Court characterised anticipatory bail as a misnomer holding that it is "granted" not in anticipation of arrest" but "in the event of arrest". It further held that "manifestly there is no question of release on bail unless a person is arrested, and therefore it is only on arrest that the order granting anticipatory bail becomes effective". The above decision could not have gone unnoticed by the four Judges in the Gurbaksh's case, the fifth Judge being Justice ....