Louis Anthony Raj Vs The State rep by The Inspector of… — Cheating and Forgery | Madras HC (2026)

Louis Anthony Raj Vs The State rep by The Inspector of… — Cheating and Forgery | Madras HC (2026)

What the court decided

AI extract

Outcome

Criminal Original Petition disposed of with directions: respondent police to follow the procedure laid down by the Supreme Court in Satender Kumar Antil v. Central Bureau Of Investigation ((2026 INSC 115) : 2025 SCC OnLine SC 1578); Investigating Officer to register F.I.R or close the petition enquiry within two weeks; parties to cooperate with the enquiry; no coercive steps against the accused till completion of enquiry. Bail was neither granted nor refused as such.

Issue for consideration

Whether the petitioner, who apprehends arrest in connection with Crime No. Not Known of 2026 for alleged offences under Sections 318(4) of BNS and Section 420 of IPC, is entitled to anticipatory bail under Section 482 of BNSS.

Court's answer

Since enquiry is pending, the Court held that the respondent Police may be directed to follow the procedure laid down by the Hon'ble Supreme Court in Satender Kumar Antil v. Central Bureau Of Investigation.

Ratio / Principle

The Investigating Officer has to conduct the enquiry by strictly following the procedures laid down in Satender Kumar Antil and, if a prima facie case is made out against the petitioner, act accordingly.

Key takeaways

If a prima facie case is made out, the police must register the F.I.R, or else close the petition enquiry, within a period of two weeks.ratio¶21
Both parties were directed to cooperate with the enquiry.ratio¶21
The respondent police shall not take any coercive steps to secure the accused until completion of the enquiry conducted on the complaint lodged by the defacto complainant.ratio

Detailed headnote1 paragraphs

Anticipatory bail — Criminal Original Petition under S.482 BNSS — petitioner apprehends arrest in Crime No. Not Known of 2026 for offences punishable under S.318(4) BNS and S.420 IPC — enquiry pending against petitioner — High Court of Madras directed the respondent police to follow the procedure laid down by the Supreme Court in Satender Kumar Antil v. Central Bureau Of Investigation ((2026 INSC 115) : 2025 SCC OnLine SC 1578); Investigating Officer to conduct the enquiry strictly per that procedure and, if a prima facie case is made out, register the F.I.R or close the petition enquiry within two weeks — parties to cooperate with the enquiry — no coercive steps to secure the accused till completion of enquiry — petition disposed of (C.Kumarappan, J.).

CRL OP No. 17875 of 2026

IN THE HIGH COURT OF JUDICATURE AT MADRAS

DATED: 10-07-2026

CORAM

THE HON'BLE MR.JUSTICE C.KUMARAPPAN

CRL OP No. 17875 of 2026

Louis Anthony Raj No.61A/6, Dhanamani Colony, Duraisamypuram, Palakkarai, Tiruchirappalli - 600029.

..Petitioner(s)

Vs

The State rep by The Inspector of Police Kodungayur Police Station, Chennai District. Crime No. Not Known of 2026.

..Respondent(s)

PRAYER:

This Criminal Original Petition is filed under Section 482 of BNSS, praying to enlarge the petitioner on Anticipatory bail in the event of his arrest in Crime No.Not Known of 2026 pending on the file of the respondent polie and thus render Justice.

For Petitioner(s): M/S. C.R.Gokulvisvas For Respondent(s): MR.N.PALANIVEL, GOVT.ADVOCATE (CRL.SIDE)

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CRL OP No. 17875 of 2026

ORDER

The petitioner apprehends arrest for the alleged offences under Sections 318(4) of BNS, Section 420 of IPC in Crime No.Not Known of 2026 on the file of the respondent police seeks anticipatory bail.

When the matter is taken up for hearing today, the learned Government Advocate (Crl.Side) appearing for the respondent submits that petitioner enquiry is pending against the petitioner.

In such circumstances, this Court is of the firm view that the respondent Police may be directed to follow the procedure 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 petitioner, 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.

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CRL OP No. 17875 of 2026

With the above directions, this criminal original petition is disposed of.

10-07-2026

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

MFA

To

The Inspector of Police Kodungayur Police Station, Chennai District.

The Public Prosecutor, High Court, Chennai.

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CRL OP No. 17875 of 2026

C.KUMARAPPAN, J.

MFA

CRL OP No. 17875 of 2026

10-07-2026

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