Successive applications for anticipatory bail are not maintainable unless there is a substantial change in circumstances; repetitive filing without new facts constitutes an abuse of the judicial process and forum shopping, warranting dismissal with exemplary costs to protect the sanctity of the judicial system.

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SUMEET GOEL, J. (Oral)

1. The present petition is the third attempt under Section 482 of Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter to be referred as ‘the BNSS’) for grant of pre-arrest/anticipatory bail to the petitioner in case bearing FIR No. 155 dated 07.12.2025 under Sections 316(2), 336(2), 338, 336(3), 61(2) of BNS and Section 13 of the Punjab Travel Professional (Regulation) Act, Police Station City Zira, District Ferozepur

The first petition bearing CRM-M-1419-2026 (Annexure P-3) for grant of pre-arrest/anticipatory bail filed before this Court was disposed of on 14.01.2026. The relevant part of said order reads as under:-

“2. After arguing for some time, learned counsel on instructions submits that the petitioner is ready to surrender before the trial Court and prays that his bail application be directed to be decided within a time bound manner.

3. In view of the prayer made, without expressing any opinion on the merits of the case, present petition is disposed of with a direction to the learned trial Court that in case the petitioner surrenders within 7 days and files an application for grant of bail, the same be decided within 2 days thereafter, in accordance with law.

Thereafter, the petitioner has preferred the second petition bearing CRM-M-4784-2026 for grant of anticipatory/pre-arrest bail before this Court which was dismissed as withdrawn vide order dated 29.01.2026 (Annexure P-4).

The present petition is the third petition for grant of anticipatory/pre-arrest bail which has been preferred by the petitioner on 25.03.2026.

2. The gravamen of the allegations, as borne out from the FIR, is that the petitioner, while acting as a travel agent in connivance with co-accused, induced the complainant and his wife on the pretext of arranging a visa for Canada. It is alleged that they have paid a substantial amount of approximately ₹1.35 lakhs to the petitioner on different occasions and also handed over their original passports and documents to the petitioner. It is further alleged that the petitioner supplied a forged visa to the complainant and, when the complainant came to know of the fraud, the petitioner returned only a part amount while retaining the balance and also failed to return the original passports. The accused persons are also alleged to have threatened the complainant when he demanded return of his money and documents. Upon these set of allegations, the instant FIR came to be registered against accused persons.

3. Learned counsel for the petitioner has iterated that the petitioner has been falsely implicated into the FIR in question and he has no connection with the alleged offence. It is contended that the petitioner has already joined the investigation on multiple occasions pursuant to interim protection and has fully cooperated with the investigation. It is also submitted that the petitioner is not involved in any other criminal case, and there is no likelihood of his absconding or tampering with the prosecution evidence. On this premise, learned counsel has argued that the instant third petition is maintainable and deserves fresh consideration. It has been further contended that there is no need for custodial interrogation of the petitioner as nothing is to be recovered from him. Furthermore, the petitioner is ready to join investigation and shall abide by all the terms and conditions that may be imposed