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2026 Supreme(P&H) 316

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
SUMEET GOEL, J.
Sonu and others – Petitioners
Versus
State of Haryana and others – Respondents
CRM-M-26377-2026 
Decided On : 11-05-2026

Advocates appeared:
For the petitioner:Mr. Sandeep Kumar Yadav, Advocate.
For Respondent:Ms. Mahima Yashpal Singla, Senior DAG Haryana, Mr. Aman, Advocate for respondent Nos.2 and 3

A second anticipatory bail petition is maintainable but requires the applicant to demonstrate a substantial change in circumstances. A private compromise between parties does not mitigate the gravity of serious offences involving forgery and cheating, nor does it constitute a sufficient ground for granting relief.

Headnote:(A) Criminal Procedure Code, 1973 - Section 438 - Bharatiya Nagarik Suraksha Sanhita - Section 482 - Anticipatory bail - Second/successive petition - Maintainability - Substantial change in circumstances - A second or successive petition for anticipatory bail is maintainable in law; however, it is not to be granted as a matter of course. The applicant is required to demonstrate a substantial change in circumstances, and a mere superficial or ostensible change is insufficient. (Paras 7, 8)

(B) Anticipatory Bail - Gravity of offence - Forgery and cheating - Where allegations involve the fabrication of government documents and the exploitation of unemployed individuals through false promises of employment, such offences have wide societal ramifications. A private compromise between the parties does not dilute the gravity of such serious offences or automatically entitle the accused to the extraordinary discretionary relief of pre-arrest bail. (Para 8)

Facts of the case:
The petitioners filed a second petition for anticipatory bail after their initial application was dismissed on merits. The prosecution alleged that the petitioners, acting in conspiracy, induced the complainant to part with money by promising government employment and providing forged appointment letters. The petitioners contended that they were victims of the principal conspirators and had reached a settlement with the complainant, providing affidavits and a compromise deed as evidence of changed circumstances.

Findings of Court:
The court observed that while a second anticipatory bail petition is legally maintainable, the petitioners failed to establish any substantial change in circumstances. The court held that the allegations of forgery and cheating, which undermine public confidence in institutional processes, are grave. The court further noted that a compromise does not negate the seriousness of the criminal conduct or the necessity of custodial interrogation to unravel the conspiracy.

Issues: The main issues were the maintainability of a second anticipatory bail petition and whether a compromise between the parties constitutes a substantial change in circumstances sufficient to warrant the grant of relief.

Ratio Decidendi: While a second anticipatory bail petition is maintainable, it requires the applicant to demonstrate a substantial change in circumstances. A compromise in cases involving serious offences like forgery and the fabrication of government documents does not dilute the gravity of the allegations or justify the grant of relief, as such acts have serious societal ramifications.

Result: Petition dismissed.

Table of Content
1. nature of the fir and factual background (Para 1 , 2)
2. contention of parties on bail and settlement (Para 3 , 4 , 5)
3. principles for assessing successive anticipatory bail petitions (Para 6 , 7 , 8)
4. final order dismissing the bail application (Para 9)

JUDGMENT

SUMEET GOEL, J. (Oral)

1. Present second petition has been filed under Section 482 BNSS/Section 438 Cr.P.C. seeking grant of anticipatory bail to the petitioners in FIR No.0022 dated 24.01.2024, registered under Sections 406 and 420 IPC and Sections 465, 467, 468 and 471 of IPC (added later on), at Police Station Sadar Narnaul, District Mahendergarh.

The petitioners had earlier applied for grant of anticipatory bail before this Court which was dismissed on merits vide order dated on 06.04.2026.

Thereafter, the present petition i.e. the second petition for grant of anticipatory bail, has been preferred by the petitioner on 06.05.2026.

2. The prosecution case, as emanating from the FIR, is that in the month of July, 2022, the complainant was approached by the accused persons namely Sonu, Vikram @ Vikram Singh and Ankush Yadav @ Ankit (petitioners herein), who represented themselves as persons having influence and connections in government departments and assured the complainant that they could secure him a job in the Air Force/Army/Military Engineering Service. It has been alleged that the accused persons induced the complainant to part with substantial amounts of money on the false promise of arranging government employment and also showed him purported government identity cards in order to gain his confidence. Acting upon such assurances/representations, the complainant initially transferred an amount of Rs.7,50,000/- through electronic means at the instance of accused Sonu (petitioner No.1 herein). Thereafter, the accused persons allegedly sent a purported appointment letter to the complainant through electronic communication and directed him to report at Chandigarh for joining and training formalities. Believing the representations to be genuine, the complainant went to Chandigarh where he was made to stay for approximately three months under the pretext of training and departmental formalities during which he incurred additional expenses. It has been further alleged that during this period, the accused persons continued to demand additional amounts from the complainant and his family members on one pretext or the other. Certain amounts were allegedly transferred through bank accounts linked with accused Ankush Yadav (petitioner No.3) and other co-accused persons, while some payments were also made in cash. As per the complainant, the total amount alleged to have been extracted from him is approximately Rs.8,00,000/-. Furthermore, the accused Vikram @ Vikram Singh (petitioner No.2) actively assured the complainant regarding the genuineness of the recruitment process and also guaranteed return of money whereas accused Ankush Yadav (petitioner No.3) facilitated the routing of funds through his bank accounts. Accused Sonu (petitioner No.1) is alleged to be the person who initially established contact with the complainant and communicated the demands and documents pertaining to the alleged appointment process. It has been further alleged that despite repeated inquiries made by the complainant regarding issuance of joining letters and posting orders, the accused persons continued to evade him and ultimately stopped responding. Upon making inquiries from the concerned department, the complainant came to know that no such recruitment process existed and the appointment letters issued to him were forged and fabricated documents. Despite repeated demands, the accused persons (petitioners herein), allegedly failed to return the money which led to registration of the instant FIR.

3. Learned counsel for the petitioners has iterated that the petitioners have falsely been implicated into the FIR in question as they are themselves the victims of the principal accused

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