R.Sujatha Vs The State Rep.by, The Inspector of Police — Cheating and Forgery | Madras HC (2026)

R.Sujatha Vs The State Rep.by, The Inspector of Police — Cheating and Forgery | Madras HC (2026)

What the court decided

AI extract

Outcome

Anticipatory bail was not adjudicated on merits; the Criminal Original Petition was disposed of with directions to the respondent police to follow the Satender Kumar Antil procedure, complete the petition enquiry (register the F.I.R or close it) within two weeks, and not take coercive steps till the completion of the enquiry.

Issue for consideration

Whether the petitioners, apprehending arrest in Crime No. Not Known of 2026 of the respondent police for alleged offences under Sections 318(4) and 316(2) of BNS Act, 2023, should be enlarged on anticipatory bail.

Court's answer

The respondent Police were directed to follow the ratio laid down by the Hon'ble Supreme Court in Satender Kumar Antil v. Central Bureau of Investigation, (2026 INSC 115) : 2025 SCC OnLine SC 1578, and the Investigating Officer was to conduct the enquiry by strictly following the procedures therein.

Ratio / Principle

If a prima facie case is made out against the petitioners, the Investigating Officer was to register the F.I.R or close the petition enquiry within a period of two weeks, and the parties were directed to cooperate with the enquiry.

Key takeaways

The respondent police were directed not to take any coercive steps to secure the accused till the completion of the enquiry on the complaint lodged by the defacto complainant.ratio¶21

Detailed headnote1 paragraphs

Madras High Court (C. Kumarappan, J.; 22.04.2026) disposed of an anticipatory bail application under Section 482 of the Bharatiya Nagarik Suraksha Sanhita Act, 2023 filed by two persons apprehending arrest in Crime No. Not Known of 2026 of T-4, Maduravoyal Police Station, Tiruvallur District, for alleged offences under Sections 318(4) and 316(2) of BNS Act, 2023 (stated in the judgment to correspond to Sections 420 and 460 IPC). On being informed that the petition enquiry was pending, the Court directed the respondent police to follow the ratio in Satender Kumar Antil v. Central Bureau of Investigation, (2026 INSC 115) : 2025 SCC OnLine SC 1578, to conduct the enquiry strictly per those procedures, to register an F.I.R or close the petition enquiry within two weeks if a prima facie case was made out, and not to take any coercive steps till the completion of the enquiry.

Crl.O.P.No.10156 of 2026 IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED : 22.04.2026

CORAM

THE HONOURABLE Mr. JUSTICE C.KUMARAPPAN

Crl.O.P.No.10156 of 2026

1.R.Sujatha 2.J.Ramanathan ... Petitioners

Vs.

The State Rep. by The Inspector of Police, T-4, Maduravoyal Police Station, Tiruvallur District. Crime No.Not Known of 2026

... Respondent

PRAYER : Criminal Original Petition filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, Act, 2023, praying to enlarge the petitioners on anticipatory bail in the event of their arrest in Crime No.Not Known of 2026 pending on the file of the respondent police.

For Petitioners : Ms.D.Lakshmipathy

For Respondent : Mr.P.Dhileepan, Government Advocate (Crl.Side)

O R D E R

The petitioners were apprehend arrest for the alleged offence under

Sections 318(4) and 316(2) of BNS Act, 2023 (Corresponding Sections 420 and 460 IPC) in Crime No.Not Known of 2026 on the file of the respondent police seeks anticipatory bail.

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Today, when the matter was taken up for hearing, the learned

Crl.O.P.No.10156 of 2026

2. Today, when the matter was taken up for hearing, the learned Government Advocate (Crl.Side) appearing for the respondent Police submitted that the petition enquiry is pending against the petitioners.

3. In such circumstances, this Court is of the firm view that the respondent Police may be directed to follow the ratio as laid down by the Hon’ble Supreme Court in Satender Kumar Antil v. Central Bureau of Investigation reported in (2026 INSC 115) and 2025 SCC OnLine SC 1578 and the Investigating Officer has to conduct the enquiry by strictly following the procedures therein and if any prima facie case is made out against the petitioners, register the F.I.R or close the petition enquiry within a period of two weeks from today. The parties are directed to cooperate with the enquiry. It is needless to say that the respondent police shall not take any coercive steps to secure the accused till the completion of enquiry, on the complaint lodged by the defacto complainant.

4. With the above directions, this Criminal Original Petition is disposed

of.

22.04.2026

cda

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Crl.O.P.No.10156 of 2026

To

1.The Inspector of Police, T-4, Maduravoyal Police Station, Tiruvallur District.

2.The Public Prosecutor, High Court of Madras.

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Crl.O.P.No.10156 of 2026

C.KUMARAPPAN.J.

cda

Crl.OP.No.10156 of 2026

22.04.2026

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