A second or successive petition for anticipatory bail is maintainable but requires a substantial change in circumstances to succeed. Repetitive filings for the same relief without such changes constitute an abuse of the judicial process and may be dismissed with exemplary costs.

JUDGMENT :

SUMEET GOEL, J.

1. Present petition is the second attempt under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (for short ‘BNSS’) for grant of anticipatory bail to the petitioner, in case bearing FIR No.83 dated 24.06.2025, registered for the offences punishable under Sections 318(4), 61(2) of the , 2023 (Sections 420, 120-B of IPC) and Section 13 of the Punjab Travel Professional (Regulation) Act, 2014, at Police Station Kathu Nangal, Amritsar Rural, District Amritsar.

2. The petitioner had earlier applied for grant of anticipatory bail in the FIR in question, before this Court, which came to be dismissed as withdrawn on 08.10.2025.

3. The gravamen of the allegations against the petitioner is that the complainant, Inderpal Singh, stated that he was introduced to the petitioner through his son-in-law, namely, Vikas, who informed him that his friend – Pargat had also applied for travel to Dubai through the petitioner. The petitioner, who is stated to be working at an immigration office located at Bittu Trade Centre, Behrampur, near Dodwa, introduced the complainant, his son – Jit Pal, and his son-in – law Vikas to a travel agent, namely, Ranjit Singh. At the instance of the petitioner, they met Ranjit Singh at his cloth showroom in Mukerian. It was agreed that a sum of Rs.44 lakhs would be paid for facilitating Jit Pal’s travel to America, out of which Rs.15 lakhs was to be paid upfront and the remaining Rs.29 lakhs after crossing the Mexico border. It is further alleged that, as per the directions of co-accused Ranjit Singh, the complainant initially transferred Rs.1,00,000/- online into the bank account of the petitioner’s brother, namely, Sourav Sahota. Thereafter, the complainant paid various amounts to co-accused Ranjit Singh on different dates. Subsequently, Jit Pal Singh was sent to Gohana. However, Ranjit Singh later began demanding additional money from the complainant on the pretext that further payment was required by agents (“donkers”) to facilitate Jit Pal’s entry into America by crossing the Mexican border. Although the complainant continued to make payments as demanded, his son was not sent to America. The complainant last spoke to his son on 21.12.2024, and since then, he has neither received any communication from him nor has any knowledge of his whereabouts.

4. Learned counsel for the petitioner has argued that the petitioner has been falsely implicated into the FIR in question. Learned counsel has argued that the complainant and the petitioner are known to each other, and the alleged payment of Rs.1 lakh had been transferred on the same day into the account of co-accused Ranjit Singh. Learned counsel has further argued that except the aforesaid transaction, there is no other allegation against the petitioner and, thus, the petitioner has nothing to do with the offence in question. Learned counsel has argued that the petitioner was merely an employee working in the Immigration office in question. Learned counsel has further submitted that there not even any agreement between the complainant and the petitioner to send son of the complaint abroad. Learned counsel has submitted that now the challan has been presented qua co-accused, namely, Joginder Lal.

4.1. Learned counsel has argued that nothing is to be recovered from the petitioner. Learned counsel has further iterated that the petitioner is ready and willing to join investigation, and no purpose would be served by keeping the petitioner behind bars. On the basis of the aforementioned submissions, grant of the