D Aranganathan Vs State Rep. by The Inspector of Police — Cheating and Forgery | Madras HC (2026)

D Aranganathan Vs State Rep. by The Inspector of Police — Cheating and Forgery | Madras HC (2026)

What the court decided

AI extract

Outcome

Petition disposed of with directions: respondent Police to follow the ratio in Satender Kumar Antil v. CBI ((2026 INSC 115); 2025 SCC OnLine SC 1578); Investigating Officer to conduct the CSR enquiry strictly per those procedures and register the F.I.R or close the petition enquiry within two weeks if a prima facie case is made out; parties to cooperate; and no coercive steps against the petitioners till completion of the enquiry on the defacto complainant's complaint.

Issue for consideration

Whether the petitioners, who apprehend arrest in connection with Crime No. Not Known of 2026 (CSR enquiry pending) for offences under Sections 316(2), 318(1), 336(2), 336(3) r/w Section 61(2) of BNS Act 2023, are entitled to anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

Court's answer

This Court held the firm view that the respondent Police may be 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).

Ratio / Principle

The Investigating Officer is to conduct the enquiry by strictly following the procedures laid down in the said Supreme Court decisions, and if a 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; the parties are directed to cooperate with the enquiry.

Key takeaways

The respondent police shall not take any coercive steps to secure the accused till the completion of the enquiry on the complaint lodged by the defacto complainant.ratio¶21
With the above directions, the Criminal Original Petition stands disposed of.ratio¶22

Detailed headnote1 paragraphs

Anticipatory Bail – Pre-FIR stage – Petition under S.482 Bharatiya Nagarik Suraksha Sanhita, 2023 by persons apprehending arrest for offences u/Ss.316(2), 318(1), 336(2), 336(3) r/w 61(2) BNS Act 2023, Crime No. Not Known of 2026, District Crime Branch-II, Tiruvallur – CSR enquiry pending – Court directs respondent Police to follow ratio in Satender Kumar Antil v. Central Bureau of Investigation ((2026 INSC 115); 2025 SCC OnLine SC 1578) – Investigating Officer to conduct enquiry strictly per those procedures, register F.I.R or close petition enquiry within two weeks if prima facie case made out – parties to cooperate – no coercive steps till completion of enquiry on defacto complainant's complaint – Criminal Original Petition disposed of.

CRL OP No. 15849 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 23-06-2026

CORAM

THE HON'BLE MR.JUSTICE C.KUMARAPPAN

CRL OP No. 15849 of 2026

D.Aranganathan 2. A.Mayuri

..Petitioners

Vs

State Rep. by The Inspector of Police, District Crime Branch-II (DCB), Tiruvallur District. O/o. SP Office, Tiruvallur 602 001. [Crime No. Not Known of 2026]

..Respondent

PRAYER: Criminal Original Petition filed under Section 482 of Bharatiya Nagarik Suraksha Sanhita, 2023, praying to enlarge the petitioners on Anticipatory Bail in the event of arrest by the respondent police in Crime Number Not Known of 2026 on the file of respondents police.

For Petitioners: Mr.B.Gandhi For Respondent: Ms.R.S.Indira Government Advocate (Crl.Side)

ORDER

The petitioners apprehend arrest for the alleged offence under Sections 316(2), 318(1), 336(2), 336(3) and r/w Under Section 61(2) of BNS Act 2023, (Bharatiya Nyaya Sanhita) in Crime No. Not known of 2026, on the file of the respondent police seek anticipatory bail.

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CRL OP No. 15849 of 2026

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

Government Advocate (Criminal Side) appearing for the respondent Police submitted that CSR 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.

23-06-2026

Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No

VEDA

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CRL OP No. 15849 of 2026

C.KUMARAPPAN, J.

VEDA

To

1.The Inspector of Police, District Crime Branch-II (DCB), Tiruvallur District. O/o. SP Office, Tiruvallur 602 001.

2.The Public Prosecutor, Madras High Court.

CRL OP No. 15849 of 2026

23-06-2026

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