Dismissed¶26

Dipender Partap Singh @ Dipen Rana v. National Investigation Agency

Punjab & Haryana HC27 Apr 2026CRA-D/329/2026

Case brief

AI extract

What is this about?

default bail; Section 187(3) BNSS 2023; Section 167(2) CrPC; Section 43D(2) UAP Act; extension of investigation period; Public Prosecutor report sealed cover; Annexure A4; Assistant Investigating Officer; Sub Inspector; Special Judge NIA Punjab; 60 days extension; NIA RC 22/2025/NIA/DLI; FIR No. 57 PS Maqsudan Jalandhar; BNS 109, 61(2), 48; Explosive Substance Act 1908 Sections 3/4/5; Arms Act Sections 25/54/5; UAP Act Sections 13/16/17/18/18B/20; Punjab and Haryana High Court; CRA-D-329-2026; Dipender Partap Singh @ Dipen Rana; National Investigation Agency

What did the court decide?

The time for completion of investigation was extended on the basis of the Public Prosecutor's sealed-cover report (Annexure A4), not on the basis of the application filed by the Assisting Investigating Officer. ¶25

Dipender Partap Singh @ Dipen Rana Vs National Investigation Agency — Punjab & Haryana HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Dismissed

¶26

Issue for consideration

Whether the appellant was entitled to default bail under Section 187(3) of BNSS 2023, given that the investigation was allegedly not completed within the limited time and the extension application was filed by the Sub Inspector of Police / Assisting Investigating Officer, who was claimed not to be the authorised person. +1 more

¶23

Court's answer

There is no illegality in the extension order; once the time was extended in accordance with law, there was no occasion to grant default bail under Section 187(3) of BNSS 2023, and the appeal is consequently dismissed.

¶26

Ratio / Principle

¶25

Key takeaways

Extension of the investigation period on the basis of the Public Prosecutor's report falls within the legal requirements of Section 43D(2) of the UAP Act.ratio¶25

Detailed headnote1 paragraphs

CRA-D-329-2026, High Court of Punjab and Haryana at Chandigarh (Anoop Chitkara and Sukhvinder Kaur, JJ.), pronounced 27.04.2026: Criminal appeal against the trial-court order dated 2nd February 2026 rejecting the appellant's default bail application under Section 187(3) of BNSS 2023 (corresponding to Section 167(2) of CrPC) in NIA case RC No. 22/2025/NIA/DLI dated 18.12.2025 arising out of FIR No. 57 dated 16.03.2025, PS Maqsudan, Jalandhar (Sections 109, 61(2), 48 BNS; Sections 3/4/5 Explosive Substance Act 1908; Sections 25/54/5 Arms Act; Sections 13/16/17/18/18B/20 UAP Act). The investigation was not completed within the statutory period; the Public Prosecutor's report was placed before the trial Court in a sealed cover (Annexure A4), and on that report the learned Special Judge, NIA Punjab extended the investigation period by 60 days on 6th January 2026, although the extension application was moved by the Assistant Investigating Officer. Held: the extension rested on the Public Prosecutor's sealed-cover report and not on the Assisting Investigating Officer's application, and such an approach falls within the legal requirements of Section 43D(2) of the UAP Act; the extension being in accordance with law, there was no occasion to grant default bail under Section 187(3) of BNSS 2023. Appeal dismissed; all pending applications disposed of.

¶1

CRA-D-329-2026

¶2

¶3

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

¶4

CRA-D-329-2026

¶5

JUDGEMENT	JUDGEMENT	OPERATIVE PART	UPLOADED ON
RESERVED ON	PRONOUNCED ON	PRONOUNCED OR FULL
09.04.2026	27.04.2026	FULL PRONOUNCED	27.04.2026

¶6

Dipender Partap Singh @ Dipen Rana

¶7

...Appellant

¶8

Versus

¶9

National Investigation Agency …Respondent

¶10

CORAM: HON'BLE MR. JUSTICE ANOOP CHITKARA HON’BLE MRS. JUSTICE SUKHVINDER KAUR

¶11

Present: Ms. Rajvinder Kaur Sohal, Advocate for the appellant.

¶12

Mr. Sukhdeep Singh Sandhu, Advocate For the respondent-NIA.

¶13

¶14

ANOOP CHITKARA, J.

¶15

RC No.	Dated	Police Stat	ion	Section
22/2025/NIA/DLI dated 18.12.2025 arising out of FIR No.57	16.03.2025	Maqsudan, Jalandhar		109, 61(2), 48 BNS Sections 3/4/5 Explosive Substance 1908, Sections 25/54/5 Arms Act and Sec 13/16/17/18/18B/20 UAP Act	and of Act 9 of tions of
Criminal Case number	before the Ses	sions Court	CIS N CNR	o.BA/143/2026 No.PBSA01000574-2026
Date of Decision			02.02.	2026

¶16

Aggrieved by the order dated 2^nd February 2026, vide which, the bail application of the appellant under Section 187(3) of BNSS 2023, which corresponds to Section 167(2) of CrPC, was rejected, the appellant had come up before this Court by filing the present appeal.

¶17

The investigation could not be completed within the statutory time limit and as such vide Annexure A4 (Page 31) a report of the Public Prosecutor was placed before the trial Court in a sealed cover. The some of the contents of the report are mentioned in Annexure

¶18

ANJU RANI 2026.04.27 16:45 I attest to the accuracy and integrity of this document Punjab and Haryana High Court Chandigarh

¶19

¶20

CRA-D-329-2026

¶21

A4, but this Court is not referring to the same. After that an application for extension of period to investigate was filed on behalf of the Assistant Investigating Officer and this application is dated 5^th January 2026.

¶22

Subsequently vide impugned order 6^th January 2026, learned Special Judge, NIA Punjab, allowed the application and extended the time to complete investigation by 60 days.

¶23

After that the applicant filed an application for default bail on the grounds that the investigation was not completed within limited time and the application for extension was filed by Sub Inspector of Police, Assisting Investigating Officer which was not the authorized person, however vide order dated 2^nd February 2026, learned trial Judge dismissed the application for default bail. Feeling aggrieved the appellant has come up before this court by filing the present appeal.

¶24

We have heard counsel for the parties and gone through the pleadings and its analysis would lead to the following outcome.

¶25

In the present case, the extension of time was not sought by the investigator, but a report was duly submitted by the Public Prosecutor under a sealed cover as Annexure A4. It was this report, based on which, the application was filed by the concerned investigator. Thus, on the face of it, the time was extended not on the basis of the application filed by the Assisting Investigating Officer, but on the report of the Public Prosecutor and such an approach falls within the legal requirements of Section 43D(2) of UAP Act.

¶26

Given the above there is no illegality in the said order and once the time was extended in accordance with law, there was no occasion to grant default bail under 187(3) of BNSS 2023. Consequently, the present appeal is dismissed. All pending applications, if any, stand disposed of.

¶27

(ANOOP CHITKARA)

¶28

JUDGE

¶29

(SUKHVINDER KAUR) JUDGE

¶30

27.04.2026
Anju rani
Whether speaking/reasoned	YES
Whether reportable	NO

¶31

ANJU RANI 2026.04.27 16:45 I attest to the accuracy and integrity of this document Punjab and Haryana High Court Chandigarh

Dipender Partap Singh @ Dipen Rana v. National Investigation Agency

Case brief

What is this about?

What did the court decide?

Dipender Partap Singh @ Dipen Rana v. National Investigation Agency

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

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