The SC in the matter of CBI v/s Vikash Mishra observed that the decision given in CBI v/s Anupam J Kulkarni that there should be no police custody beyond 15 days of arrest should be reconsidered.

The court granted permission to CBI to have 4 days of police custody of the accused whose remand was originally granted for 7 days by the special court. 

 However, CBI could only interrogate for a period of two and half days considering that the accused was hospitalized in the interim and was eventually released on interim bail.

Taking into consideration that the CBI could interrogate the respondent only for a period of two and half days during the period of police remand and therefore could not exercise the right of interrogation for the full period of seven days, the Court permitted the CBI to have the police custody of the respondent for a period of four days.

The Court noted that when one is on bail, there cannot be any police custody and therefore in the present case, the CBI could not interrogate the respondent for the full seven days of remand granted by the Special Court.

Considering the observations of the Special Court concerning the misuse of liberty and non-cooperation with the CBI, the Supreme  Court observed that its decision in Anupam J. Kulkarni, wherein it was observed that there cannot be police custody beyond 15 days from the date of arrest, needs to be reconsidered.