Arnesh Kumar v. State of Bihar, (2014) 8 SCC 273:

The Supreme Court emphasized the need for police officers to justify arrests, particularly for offences punishable with imprisonment up to seven years, promoting release on bail or bond rather than automatic arrest and detention. This reinforces the statutory modes of discharge mentioned in Section 59.

Kapoor Chand v. State of Rajasthan, 1973 CriLJ 726 (Raj):

This High Court ruling affirmed that once a person is arrested by a police officer, their discharge can only occur through the specific modes prescribed in Section 59, namely, on their own bond, on bail, or by a special order of a Magistrate, thereby limiting the discretion of the police in discharging arrested persons.