Dismissed¶33

Anand Paswan Alias Panga v. the State of NCT of Delhi and Anr.

Delhi HC20 Apr 2026BAIL APPLN./1508/2026

Case brief

AI extract

What is this about?

forged vakalatnama; white fluid tampering; pairokar misuse; bail application dismissed as withdrawn; undated attestation endorsement; Registry scrutiny of bail filings; practice directions; Registrar General; Chief Justice; FIR No. 108/2021 PS Patel Nagar; Sections 307/323/34 IPC; Delhi High Court; Girish Kathpalia; Anand Paswan alias Panga; associate counsel Sanjay Kumar; pairokar Munna Lal; Shefali Barnala Tandon Tis Hazari Courts; State vs Anand Paswan; COVID-era pairokari filings; personal signing by prisoners in jail.

What did the court decide?

Withdrawal of the bail application and the accompanying application permitted; both dismissed as withdrawn. No relief on the bail merits. ¶33

Anand Paswan Alias Panga Vs the State of NCT of Delhi and Anr. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Withdrawal of the bail application and the accompanying application permitted; both dismissed as withdrawn. No relief on the bail merits.

¶33

Issue for consideration

Whether the accused/applicant Anand Paswan alias Panga is entitled to regular bail in FIR No. 108/2021 of Police Station Patel Nagar for offences under Sections 307/323/34 IPC. +2 more

¶11

Court's answer

At the request of learned counsel for the accused/applicant, the bail application and the accompanying application (CRL.M.A. 11975/2026) were dismissed as withdrawn; the bail question on merits was not decided.

¶33

Ratio / Principle

The vakalatnama filed with the bail application appears to have been forged: the title of the court and the case was found covered with white fluid and thereafter the title of this Court and this case was typewritten, while the rest of the vakalatnama is handwritten.

¶23

Key takeaways

On being called upon to show the original vakalatnama, learned counsel produced a photocopy of the same vakalatnama bearing the title of the court as Ms. Shefali Barnala Tandon, Tis Hazari Courts, and the title of the case as State vs Anand Paswan, indicating its origin in a trial court filing.ratio¶26
Someone applied white fluid on the vakalatnama filed before the trial court and used the same vakalatnama for filing this bail application.ratio¶27

Detailed headnote1 paragraphs

BAIL APPLN. 1508/2026 & CRL.M.A. 11975/2026 — Anand Paswan alias Panga v. The State of NCT of Delhi & Anr. (Delhi High Court, Girish Kathpalia J., 20.04.2026): Regular bail sought in FIR No. 108/2021, PS Patel Nagar, under Sections 307/323/34 IPC. The application, filed through pairokar Mr. Munna Lal, was dismissed as withdrawn at the request of learned counsel. Examining the vakalatnama, the Court found it apparently forged — the original title (Ms. Shefali Barnala Tandon, Tis Hazari Courts; case 'State vs Anand Paswan') had been covered with white fluid and replaced with the title of this Court and case; the signatory was 'Anand' although the pairokar was Munna Lal; and the trial court's attestation endorsement was undated. The supporting affidavit recorded 'NA' against previous bail applications, yet the Registry cleared the filing. The Court observed frequent misuse of the pairokari system (resorted to during the COVID period) and stated that the High Court needs to consider discontinuing filings through pairokars, requiring each filing to be signed personally by the prisoner in jail. Copies of the order were directed to the Registrar General (for the Hon'ble Chief Justice, for necessary Practice Directions) and, with the vakalatnama (printed page No. 117 of the paperbook), to the trial court to ascertain the genuineness of the undated attestation.

¶1

$~61

¶2

IN THE HIGH COURT OF DELHI AT NEW DELHI

¶3

- BAIL APPLN. 1508/2026 & CRL.M.A. 11975/2026

¶4

ANAND PASWAN ALIAS PANGA .....Petitioner

¶5

Through: Mr. Pankaj Kumar, Advocate

¶6

versus

¶7

THE STATE OF NCT OF DELHI AND ANR .....Respondents

¶8

Through: Mr. Sanjeev Sabharwal, APP for State with Inspector Naveen Kumar and SI Dharmendra Sharma

¶9

CORAM: HON'BLE MR. JUSTICE GIRISH KATHPALIA

¶10

O R D E R % 20.04.2026

¶11

The accused/applicant seeks regular bail in case FIR No. 108/2021 of Police Station Patel Nagar for offence under Section 307/323/34 IPC.

¶12

It is considered apposite, so order passed today itself in Bail Application No. 1507/2026 in which same counsel has appeared is extracted below:

¶13

“1. The accused/applicant seeks regular bail in case FIR No. 644/2023 of Police Station Moti Nagar for offence under Section 307/34 IPC & Section 25/27/54/59 of the Arms Act.

¶14

2. It appears that earlier, vide order dated 12.02.2026, the bail application bearing No. 1880/2025 of the accused/applicant was dismissed as withdrawn with liberty to file afresh before the trial court subsequent to the testimony of the injured Raju, who had not been appearing before the trial court. The injured Raju appeared and supported prosecution case in his testimony. Thereafter, the accused/applicant filed fresh bail application before the Court of Sessions, which was dismissed vide order dated 30.03.2026. By way of detailed reasons, described in paragraph 6 of the order dated

¶15

This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/04/2026 at 11:36:23

¶16

30.03.2026, the learned trial court dismissed the bail application. After that, the present application has been filed.

¶17

3. At the outset, learned APP for State submits that the accused/applicant has also filed an interim bail application, which is pending before the trial court. In other words, the accused/applicant is proceeding before two courts simultaneously.

¶18

4. Further, it is found that the present bail application is not even accompanied with vakalatnama of the accused/applicant. That, apparently was to avoid any consequences of filing this application during pendency of the application before the trial court.

¶19

5. At this stage, learned counsel for accused/applicant seeks permission to withdraw this bail application.

¶20

6. As requested, the bail application and the accompanying application are dismissed as withdrawn.”

¶21

Present case is yet another case on similar lines when it comes to the vakalatnama . Since the present case came up immediately after the order passed in Bail Application No. 1507/2026, in order to rule out any mischief, I examined the affidavit supporting the bail application and the vakalatnama .

¶22

The bail application has been filed through pairokar Mr. Munna Lal. In the supporting affidavit, the relevant column No. 5 as regards previous bail applications simply mentions NA. But the Registry, in its wisdom cleared the application and placed it for hearing.

¶23

More shocking is that the vakalatnama filed with the bail application appears to have been forged. Title of the court and the case in the vakalatnama was found covered with white fluid and thereafter, title of this Court and the case were typewritten while rest of the vakalatnama is handwritten. Even name of the litigant signing the vakalatnama is Anand while the pairokar is Munna Lal. Registry seems to have ignored this also.

¶24

This is a digitally signed order.

¶25

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/04/2026 at 11:36:23

¶26

Further, on being called upon to show the original vakalatnama , learned counsel for accused/applicant produced a photocopy of the vakalatnama . It is the same vakalatnama but bears title of the court as Ms. Shefali Barnala Tandon, Tis Hazari Courts and title of the case as State vs Anand Paswan .

¶27

It appears that for filing this bail application, someone applied white fluid on the vakalatnama filed before the trial court and used the same for filing this bail application.

¶28

It is also observed that attestation endorsement of the trial court on the vakalatnama is undated. 9. On being confronted with the aforesaid, learned counsel for accused/applicant submits that it is his associate counsel Mr. Sanjay Kumar, who is responsible for this tampering. It is submitted by learned counsel for accused/applicant that he had handed over the brief to Mr. Sanjay Kumar, Advocate only for the purposes of filing this Bail Application. 10. It is indeed a matter of concern that the system of pairokari is often being misused. It is during the covid period that the Advocates were allowed to file the petitions/applications through pairokars so that they do not have to visit the jail and get the pleadings signed by the prisoners. When it comes to taking action in such cases, the pairokar goes unscathed and even the petitioner/applicant prisoner cannot be penalized as she/he might not even be aware about the proceedings. Now that there is no more pandemic situation, the High Court needs to consider as to whether such system of filings through pairokars be discontinued, directing that each filing be signed by the petitioner/applicant prisoner personally in jail, for which the counsel personally or through clerk would visit the jail.

¶29

This is a digitally signed order.

¶30

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 21/04/2026 at 11:36:23

¶31

Copy of this order be sent to the worthy Registrar General of this Court for placing it before the Hon’ble Chief Justice for necessary Practice Directions. Copy of this order along with a copy of the vakalatnama ( printed page No. 117 of paperbook ) be also sent to the learned trial court to ascertain the genuineness of the attestation of the vakalatnama , which attestation is undated.

¶32

At this stage, learned counsel for accused/applicant seeks permission to withdraw this bail application.

¶33

As requested, the bail application and the accompanying application are dismissed as withdrawn.

¶34

GIRISH KATHPALIA, J

¶35

APRIL 20, 2026/as

¶36

Anand Paswan Alias Panga v. the State of NCT of Delhi and Anr.

Case brief

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What did the court decide?

Anand Paswan Alias Panga v. the State of NCT of Delhi and Anr.

Case brief

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What the court decided

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