The Supreme Court of India in the case of State of Haryana v. Danesh Kumar (2008) held that 'arrest' implies:

A. Apprehension of the accused by the police officer

B. Apprehension of the accused by the police officer or the submission of the accused to the custody by word or action including when he is in the judicial custody on surrender before the court and/or submits to its direction

C. Handcuffing of the accused by the police officer

D. Handcuffing and putting the accused in police or judicial custody

Answer: Option B