Allowed¶28

Satish Kumar v. State of Haryana

Punjab & Haryana HC21 Jul 2025CRM-M/562/2025

Case brief

AI extract

What is this about?

Satish Kumar v. State of Haryana; CRM-M-562-2025 (O&M); High Court of Punjab and Haryana at Chandigarh; Sandeep Moudgil, J. (oral); decided 21.07.2025; anticipatory bail; Section 482 BNSS 2023; Section 482(2) BNSS 2023; FIR No. 302 dated 21.07.2024; Sections 406 and 420 IPC; Police Station Meham, District Rohtak; interim anticipatory bail dated 10.01.2025 made absolute; petitioner joined investigation; voice sample comparison; recovery of Rs. 25 lakhs pending; petition allowed and disposed.

What did the court decide?

Concession of anticipatory bail — interim anticipatory bail granted vide order dated 10.01.2025 made absolute; petition disposed of accordingly. ¶28

Satish Kumar Vs State of Haryana — Cheating and Forgery | Punjab & Haryana HC (2025)

What the court decided

AI extract

Outcome

Concession of anticipatory bail — interim anticipatory bail granted vide order dated 10.01.2025 made absolute; petition disposed of accordingly.

¶28

Issue for consideration

Whether the petitioner, arrayed in FIR No. 302 dated 21.07.2024 under Sections 406 and 420 IPC registered at Police Station Meham, District Rohtak, Haryana, is entitled to the concession of anticipatory bail under Section 482 BNSS 2023.

¶14

Court's answer

Once the petitioner had been granted interim anticipatory bail on 10.01.2025 and had admittedly joined the investigation in pursuance thereof, keeping the petition pending for one or the other reason would be of no use.

¶23

Ratio / Principle

This Court cannot monitor and examine the direction of an investigation on a day-to-day basis in each and every case, especially where interim anticipatory bail has been granted and the petitioner has joined the investigation.

¶27

Key takeaways

The Court did not deem it necessary to have any further indulgence in the matter; the petition was allowed and the order dated 10.01.2025 (granting interim anticipatory bail) was made absolute.ratio¶28

Detailed headnote1 paragraphs

Anticipatory bail — Petition under Section 482 BNSS 2023 in FIR No. 302 dated 21.07.2024, Sections 406 and 420 IPC, Police Station Meham, District Rohtak, Haryana — Interim anticipatory bail granted on judicial order dated 10.01.2025 subject to furnishing personal/surety bonds — Petitioner admittedly joined investigation and consented to voice-sample comparison with an audio recording; State flagged unrecovered amount of Rs. 25 lakhs — Held: once interim anticipatory bail has been granted and the petitioner has admittedly joined the investigation, keeping the petition pending for one or the other reason would be of no use; the Court cannot monitor and examine the direction of investigation on a day-to-day basis in each and every case — Petition allowed and order dated 10.01.2025 made absolute; petition disposed of.

¶1

215

¶2

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

¶3

CRM-M-562-2025 (O&M) DATE OF DECISION : 21.07.2025

¶4

SATISH KUMAR

¶5

.......PETITIONER(s)

¶6

VERSUS

¶7

STATE OF HARYANA

¶8

.....RESPONDENT(s)

¶9

CORAM: HON'BLE MR. JUSTICE SANDEEP MOUDGIL

¶10

Present: Dr. Pankaj Nanhera, Advocate and Mr. Yogesh Vashisth, Advocate for the petitioner(s).

¶11

Ms. Mayuri Lakhanpal Kalia, DAG, Haryana.

¶12

¶13

SANDEEP MOUDGIL, J.(Oral)

¶14

The instant petition under Section 482 of Bharatiya Nagarik Surkasha Sanhita 2023 (BNSS-2023) for granting the concession of anticipatory bail to the petitioner in FIR No. 302 dated 21.07.2024 under Sections 406 and 420 of India Penal Code registered at Police Station Meham, District Rohtak, Haryana, in the interest of justice.

¶15

A perusal of the file shows that on the judicial order dated 10.01.2025, the petitioner was granted concession of interim anticipatory bail subject to his furnishing personal/surety bonds to the satisfaction of the investigating/Arresting officer, as and when further

¶16

Anuradha 2025.07.23 05:39 I agree to specified portions of this document

¶17

CRM-M-562-2025 (O&M)

¶18

¶19

called by the investigating officer, the petitioner shall join the investigation and shall abide by the condition(s) enumerated under Section 482(2) of BNSS, 2023. Thereafter the matter was taken up on 05.02.2025 and on the instruction learned State Counsel submitted that though the petitioner has joined investigation however, recovery of Rs. 25 lakhs had not been effected. It is also the case of the State that voices sample of the petitioner was to be obtained for matching with one audio recording wherein the petitioner is audible, taking to the complainant with respect to money transaction and promised to provide government job for complaint’s grandson.

¶20

In light of the above, the petitioner was once again directed to join the investigation as and when called by the investigating agency and cooperate with the investigating agency and the matter was adjourned to 24.04.2025.

¶21

On 24.04.2025, the instructions of the learned State Counsel were incomplete and the matter was adjourned to today and interim order was ordered to be continued till the next date of hearing.

¶22

Today, learned counsel for the petitioner would submit that the petitioner has joined the investigation in compliance to the order dated 10.01.2025 and has consented to give the sample of voice for comparison/examination with one audio alleged to have been came into possession of the investigating officer.

¶23

The Court is of the view that once the petitioner was granted interim anticipatory bail on 10.01.2025 and in pursuance thereto has admittedly joined the investigation, then keeping the petition pending for one or the other reason would be of no use.

¶24

Anuradha 2025.07.23 05:39 I agree to specified portions of this document

¶25

CRM-M-562-2025 (O&M)

¶26

¶27

In each and every case, this Court cannot monitor and examine the investigation, direction on day to day basis especially when the interim anticipatory bail has been granted to the petitioner and he has joined the investigation.

¶28

In light of the above, this Court do not deem it necessary to have any further indulgence in the matter, hence, the petition is allowed and order dated 10.01.2025 is made absolute.

¶29

Petition stands disposed of in the above terms.

¶30

21.07.2025 anuradha		(SANDEEP MOUDGIL) JUDGE
	Whether speaking/reasoned	: Yes/No
	Whether reportable	: Yes/No

¶31

Anuradha 2025.07.23 05:39 I agree to specified portions of this document

Satish Kumar v. State of Haryana

Case brief

What is this about?

What did the court decide?

Satish Kumar v. State of Haryana

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

Similar cases

Bhajan Singh Vs State of Punjab

Sukhvir Singh Alias Sukhbir Singh and Others Vs State of Punjab and Others

Vijay Khanna Vs State of Haryana

Arun Mittal Vs Harish Garg

Narender Singh Vs Rajiv Deol

Simranpreet Singh @ Rahul @ Bundi Vs State of Punjab