The malpractice of receipt origin, of ordering deposit of amount as a pre-condition for grant of anticipatory bail or regular bail, has come in for criticism by the Supreme Court of India and the High Court of Delhi. Mostly in cases under Sections 498-A/406 IPC and Section 420 IPC, trial Courts and Sessions Courts have been ordering accused persons to deposit amount equivalent to value of the alleged stridhan in cases under Sections 498-A/406 IPC and amount equi-valent to amount of cheating in cases under Section 420 IPC, as a pre-condition for being given order of protection from arrest under Section 438 of the Code of Criminal Procedure, 1973 (“the Code”) or for being released after arrest under Sections 437 and 439 of the Code. In the predicament in which an accused is placed who has been apprehending arrest or has already been arrested and seeks bail, an accused sometimes gives an undertaking to a Court to the effect that he/she will deposit requisite amount either i ....