In the High Court for the States of Punjab and Haryana at Date of Decision:- 20.01.2026 Vinod Kumar … Petitioner Versus State of Punjab ... Respondent CORAM: HON'BLE MR. JUSTICE SUBHAS MEHLA Present:- Mr. Deepak Goyal, Advocate for the petitioner.

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SUBHAS MEHLA , J. (Oral)

1. The instant petition under Section 482 of Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, has been filed for grant of anticipatory bail to the petitioner in case FIR No.301 dated 25.11.2025, registered under Section 420 of IPC, at Police Station Lehra, District Sangrur.

2. Learned counsel for the petitioner contended that the petitioner has been falsely implicated in the present case as the present FIR as a counter blast to a civil suit filed by the petitioner. It is also contended that the present case pertains to a civil dispute between the petitioner and the complainant; petitioner has paid the amount and in this regard, a notarised affidavit is annexed in the paper book as Annexure P-2. Thus, learned counsel prayed for grant of relief of anticipatory bail to the petitioner.

3. Notice of motion.

4. Mr. Anup Singh, AAG, Punjab, has put in appearance as advance copy of petition had been served to respondent-State and has opposed the prayer made by learned counsel for the petitioner by submitting that the FIR has been registered on the basis of inquiry and as per inquiry report, the petitioner has cheated the complainant on the pretext of providing a government job in Delhi in Civil Defence. Regarding compromise, signatures of complainant were obtained on a blank paper at the time of promising him government job. Learned State counsel also apprised the Court that the present petitioner is also involved in 4 other cases of similar nature i.e. FIR No.205 dated 15.11.2019, registered under Sections 420, 465, 467, 468, 471 & 120-B of IPC at Police Station City Dhuri, District Sangrur, FIR No.118 dated 31.05.2020, registered under Section 420 of IPC at Police Station Dirba, District Sangrur, FIR No.216 dated 25.12.2019, registered under Sections 420 & 120-B of IPC at Police Station Mansa, District Mansa and FIR No.99 dated 09.09.2025, registered under Sections 318(4), 336(2), 336(3) and 340(2) of BNS at Police Station Ajit Wala, District Moga.

5. Heard.

6. As per the facts and circumstances of the present case and contentions of learned counsel for the parties, the allegation against the present petitioner is of cheating the complainant of Rs.3,57,000/- on pretext of providing government job; as submitted by learned State counsel petitioner is a habitual offender and is involved in 4 more cases of similar nature. Qua the alleged compromise, learned Additional Sessions Judge, Sangrur while dismissing the bail application of present petitioner, vide order dated

03.12.2025 (Annexure P-3) has made categorical observation as follows:-

“… During inquiry, the affidavit propounded by applicant allegedly issued by the complainant having received the payment from Vinod Kumar and Gulzar Singh was found to be suspicious document and it was found that complainant had been duped by the applicant for a sum of Rs.3,57,000/- under the pretext of getting him government job in Delhi. So, I find no sufficient reason to grant him concession of anticipatory and his custodial interrogation is required for proper investigation of the case and as such, his bail applicant stands declined. ...”

7. In view of aforesaid discussion, this Court is not inclined to grant concession of anticipatory bail to the petitioner as custodial interrogation of the petitioner is required to collect the evidence and to conduct an in-depth probe to elicit the intricate details of manner of commission of offence.

8. The Hon’ble Supreme Court has emphasised the importance of custodial interrogation in case titled as ‘CBI Vs. Anil Sharma, 1997 AIR Supreme Court 3806’ decided on 03.08.1997, by holding that many useful informations and concealed materials may be elicited from a suspect in custody, than a suspect wh