Code Of Criminal Procedure, 1973; Section 437 – Section 437 would come into play when the accused is arrested or detained or when the summons or warrant is issued against the accused for causing him to be brought or to appear before the Court. In absence of any order for issuance of summons or warrant under Section 204 or under any other provision of Cr.P.C., the summons could not have been issued or served upon the appellant nor he could have been arrested or taken into custody. – When there was no order passed by the Special Court for issuance of the summons or warrant, the application of the appellant seeking bail could not have been entertained.(Para 9-10)