Dismissed¶64

Manjit Kaur v. State of Punjab

Punjab & Haryana HC10 Jul 2026CRM-M/11037/2026

Case brief

AI extract

What is this about?

Anticipatory bail refused; impersonation of property owner in sale deed dated 22.08.2024; cheating/forgery; Sections 319(2), 318(4), 338, 336(3), 340(2), 61(2) BNSS 2023 (419, 420, 467, 468, 471, 120B IPC); FIR No.150 PS Koom Kalan Ludhiana; reliance on Sumitha Pradeep v. Arun Kumar C.K. 2022(4) RCR (Criminal) 977; custodial interrogation; antecedent FIR No.41 PS Focal Point; petition dismissed; Punjab and Haryana High Court; Jasjit Singh Bedi, J.; CRM-M.

What did the court decide?

Adopting the ruling in Sumitha Pradeep v. Arun Kumar C.K.: that custodial interrogation is not required is not, by itself, a ground to grant anticipatory bail; the first and foremost thing the Court hearing an anticipatory bail application must consider is the prima facie case against the accused. ¶35

Manjit Kaur Vs State of Punjab — Anticipatory Bail | Punjab & Haryana HC (2026)

What the court decided

AI extract

Outcome

Dismissed

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Issue for consideration

Whether the petitioner, who was not named in the FIR and against whom no role is attributed in the challan filed against the co-accused, is entitled to the concession of anticipatory bail in FIR No.150 dated 28.12.2024, Police Station Koom Kalan, Ludhiana. +1 more

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Court's answer

The offence being prima facie established and the investigation to be taken to its logical conclusion, the custodial interrogation of the petitioner is certainly required; consequently the anticipatory bail petition is dismissed.

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Ratio / Principle

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Key takeaways

As per the allegations, the petitioner impersonated the real owner Sneha Sharma when the sale deed was executed on 22.08.2024, her photograph stands affixed on the said sale deed, and money transferred into her bank account shows her active connivance with the main accused.ratio¶47
The observations made in the order are only for the purpose of deciding the bail application; the Trial Court remains free to adjudicate on the evidence led before it uninfluenced by these observations.obiter¶68

Detailed headnote1 paragraphs

Punjab and Haryana High Court (Jasjit Singh Bedi, J.) dismisses an anticipatory bail application under Section 482 read with 528 BNSS in FIR No.150 dated 28.12.2024, Police Station Koom Kalan, Ludhiana, under Sections 319(2), 318(4), 338, 336(3), 340(2), 61(2) BNSS, 2023 (Sections 419, 420, 467, 468, 471, 120B IPC). Allegations: the petitioner impersonated the real owner Sneha Sharma during execution of sale deed dated 22.08.2024 (her photograph affixed and signed as Sneha Sharma), acted in connivance with Ravi Bansal, Lajpat Rai and Lekh Raj in cheating complainant Mohan Singh, and received UPI transfers from Ravi Bansal into her SBI account; she was nominated as accused vide GD No.19 dated 23.07.2025 and is also involved in FIR No.41 dated 24.04.2025, Police Station Focal Point, Ludhiana, wherein she is absconding. Relying on Sumitha Pradeep v. Arun Kumar C.K., 2022(4) RCR (Criminal) 977 — that absence of need for custodial interrogation is not by itself a ground for anticipatory bail and the prima facie case is the first consideration — the Court found the offence prima facie established and custodial interrogation required, and dismissed the petition, clarifying that its observations are confined to the bail application and do not bind the Trial Court.

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CRM-M-11037-2026 (O & M)

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IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH (204)

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CRM-M-11037-2026 (O & M) Date of decision: 10.07.2026

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Manjeet Kaur …... Petitioner

V/s

State of Punjab

...Respondent

CORAM: HON’BLE MR. JUSTICE JASJIT SINGH BEDI

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Present: Ms. Vandan Sharma, Advocate, with Ms. Rohini Bedi, Advocate, for the petitioner.

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Mr. M.S. Toor, AAG, Punjab.

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JASJIT SINGH BEDI, J. (Oral)

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The prayer in the present petition under Section 482 read with 528 BNSS is for the grant of anticipatory bail to the petitioner in case FIR No.150 dated 28.12.2024 under Sections 319(2), 318(4), 338, 336(3), 340(2), 61(2) BNSS, 2023 (Sections 419, 420, 467, 468, 471, 120B IPC) registered at Police Station Koom Kalan, Ludhiana.

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The present FIR came to be registered at the instance of one Mohan Singh and reads as under:-

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Complaint PGD No: 454702 To The Commissioner of Police Ludhiana. Subject:-Complaint against:- 1) Lajpat Rai son of Shri Ramesh Kumar resident of H.E. 205 Chandigarh Road, Jamalpur Kalai Focal Point Ludhiana 2) Ravi Bansal son of Mahavir Parshad resident of Ward No. 6 Judge Wali Street, Khanauri Kala, Pakki Khaneri, Sangrur (Mobile No. 79018-

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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41203, 79861-71309) 3) Lekh Raj son of Shri Ramesh Kumar resident of H.L. 1114 Punjab Housing Board Colony, Jamalpur, Focal Point Ludhiana 4) Sneha Sharma wife of Rajiv Kumar resident of House No. 178 Okar Vihar, 89682-62246) Jamalpur Awana, Ludhiana (Mobile No. regarding fraud and threats by them. Sir I request that I Mohan Singh son of Naseeb Singh am a resident of House No. 117-A, Street No. 2 Guru Teg Bahadur Nagar Mundia Kalan, near Chandigarh Road, Ludhiana and I complain:-That I was shown a plot area of 605 square yards, Khasra No. 86, Khata No. 130/135, Jamabandi Year 20172018, Village Latedana, Hadbast No. 214, Tehsil Sahnewal, District Ludhiana, by Ravi Bansal, son of Mahavir Parshad, resident of Ward No. 6, Judge Wali Gali, Khaneri Kalan, Pakki Khanori, Sangrur and told me that I work as a property dealer. On being shown the plot by him, I liked the plot. He also told me that the plot belongs to my relative. He sold the said plot at the rate of Rs. 8600/- per square yard to Lajpat Rai, son of Ramesh Kumar, resident of H.E. 205 Chandigarh Road, Jamalpur Colony, Focal Point Ludhiana dated 15-05-2024 and got the agreement in my name by taking a surety of Rs. 10 lakhs from me. Ravi Bansal had signed this agreement as a witness. A copy of the agreement is attached. That after this Ravi Bansal after collecting a total amount of Rs. 52.03,000/- at the rate of Rs. 8600/- per yard from me in regard to plot area measuring 605 square yards got the registration deed No. 2226 dated 2208-2024 done in my favour from the original owner Seneh Sharma, wife of Rajiv Kumar, resident of House No. 178, Ukar Vihar, Jamalpur, Ludhiana. A copy of the registration is attached. When I asked for the previous documents of the plot, registry etc., he did not give me the documents, so I suspected that Ravi Basil had made Seneh Sharma another woman

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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instead of the real woman Seneh Sharma and appeared in the tehsil and got the registration done in my name. I have paid the registration amount of Rs. 6,70,000/- through Cheque No. 064123 dated 13-08-2024 IndusInd Bank Urban Estate Ludhiana. That Ravi Bansal had also taken Rs. 3 lakh from the plot amount on my side, which I had deposited in Ravi Bansal's account number 110154170823 Canara Bank, Focal Point Ludhiana. On 23-05-2024, Rs.3,90,000/- wan transferred through RTGS. Earlier Lekh Raj son of Mr. Ramesh Kumar resident of HL 1114 Punjab Housing Board Colony, Jamalpur, Focal Point Ludhiana had taken the remaining amount of the plot in cash and Ravi Bansal has taken the entire amount on my behalf on the behalf of Suneha Sharma. That I have come to know that Ravi Bansal who is the main accused has cheated me by joining hands with the other accused Lajpat Rai, Lekh Raj and Suneha Sharma and has registered the property in my name by putting up another woman instead of the real owner Suneha Sharma. The said Ravi Bansal is the mastermind of this game. That I have also come to know that many criminal cases are going on before this and he is a criminal person. When I came to know that I had been cheated, I asked Ravi Bansal for my money back, but he started threatening me that I have connections with big officers and political leaders, you cannot harm me and said that if you complete us, the result will be very bad. I request you to file a case against the said Ravi Bansal and his associates and get justice. I will be very grateful to you. Date: 17-10-2024 Complainant SD/ Mohan Singh.

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The learned counsel for the petitioner contends that the

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petitioner has been falsely implicated in the present case. She has not been

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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named in the FIR and nor has any role been attributed to her in the challan which stands filed against the co-accused. In fact, she has been nominated as an accused on the basis of the statement of one Ravi Bansal who is one of the main accused. As the petitioner is ready and willing to join the investigation, she is entitled to the concession of anticipatory bail.

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The learned counsel for the State, on the other hand, while referring to the status report dated 07.03.2026 which is already on record, contends that during investigation, it has been found that the petitioner acted as an impersonator in the place of the real owner-Sneha Sharma during execution of sale deed dated 22.08.2024 and her photograph is affixed on the said sale deed. She acted in connivance with Ravi Bansal, Lajpat Rai and Lekh Raj in cheating the complainant-Mohan Singh and money has also been transferred into her bank account. As the offence is prima facie established and the investigation is to be taken to its logical conclusion, the custodial interrogation of the petitioner is certainly required and therefore, she is not entitled to the concession as prayed for.

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I have heard the learned counsel for the parties.

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The Hon'ble Supreme Court in the case of ‘Sumitha Pradeep

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Vs. Arun Kumar C.K. & Anr. 2022(4) RCR (Criminal) 977’, has held that merely because custodial interrogation was not required by itself could not be a ground to grant anticipatory bail. The first and the foremost thing the Court hearing the anticipatory bail application is to consider is the prima

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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facie case against the accused. The relevant extract of the judgment is reproduced hereinbelow:-

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“It may be true, as pointed out by learned counsel appearing for Respondent No.1, that charge-sheet has already been filed. It will be unfair to presume on our part that the Investigating Officer does not require Respondent No.1 for custodial interrogation for the purpose of further investigation.

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Be that as it may, even assuming it a case where Respondent No.1 is not required for custodial interrogation, we are satisfied that the High Court ought not to have granted discretionary relief of anticipatory bail.

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We are dealing with a matter wherein the original complainant (appellant herein) has come before this Court praying that the anticipatory bail granted by the High Court to the accused should be cancelled. To put it in other words, the complainant says that the High Court wrongly exercised its discretion while granting anticipatory bail to the accused in a very serious crime like POCSO and, therefore, the order passed by the High Court granting anticipatory bail to the accused should be quashed and set aside. In many anticipatory bail matters, we have noticed one common argument being canvassed that no custodial interrogation is required and, therefore, anticipatory bail may be granted. There appears to be a serious misconception of law that if no case for custodial interrogation is made out by the prosecution, then that alone would be a good ground to grant anticipatory bail. Custodial interrogation can be one of the relevant aspects to be considered along with other grounds while deciding an application seeking anticipatory bail. There may be many cases in which the custodial interrogation of the accused may

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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not be required, but that does not mean that the prima facie case against the accused should be ignored or overlooked and he should be granted anticipatory bail. The first and foremost thing that the court hearing an anticipatory bail application should consider is the prima facie case put up against the accused. Thereafter, the nature of the offence should be looked into along with the severity of the punishment. Custodial interrogation can be one of the grounds to decline custodial interrogation. However, even if custodial interrogation is not required or necessitated, by itself, cannot be a ground to grant anticipatory bail .”

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As per allegations, the petitioner impersonated the real ownerSneha Sharma when the sale deed was executed on 22.08.2024 and her photograph stands affixed on the said sale deed. Money has also been transferred into her bank account showing her active connivance with the main accused.

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The relevant extract of the status report dated 07.03.2026 filed by way of an affidavit of Inderjit Singh, PPS, Assistant Commissioner of Police, Industrial Area-A, Ludhiana, enumerating the role played by the petitioner is reproduced as under:-

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13. That during investigation it was revealed that co-accused Ravi Bansal had transferred amounts of Rs.2,000/-, Rs.3,000/and Rs.5,000/- through UPI on 19.08.2024 to Account No. 43102097009 of SBI Bank, Jamalpur, Ludhiana, belonging to Manjit Kaur (petitioner) c/o Narinder Singh, resident of Baba Fateh Singh Nagar, Street No. 09, Sukhchain Sahib Road, Kapurthala, and the bank account details of Manjit Kaur

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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(petitioner) regarding the said transactions were obtained. The records of the Revenue Department were also examined during investigation. As per the sale deed dated 22.08.2024, the photograph of Manjit Kaur (petitioner) was affixed while her name was shown as Sneha Sharma (seller), and the petitioner had also signed the name of Sneha Sharma on the said sale deed. On the basis of interrogation and documentary record, it was found that co-accused Ravi Bansal, in connivance with Manjit Kaur (petitioner), impersonated a fake Sneha Sharma in place of the real owner Sneha Sharma and got the registry executed fraudulently. Accordingly, Manjit Kaur (petitioner) was nominated as an accused in the present case vide GD No.19 dated 23.07.2025.

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XXXX XXXX

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XXXX

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21. That in compliance with the order dated 25.02.2026 passed by this Hon'ble Court, the following particulars are being submitted herein below as directed in tabular format:

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Sr. No.	Role of thepetitioner
1.	Petitioner acted as impersonator in place of real owner Sneha Sharma during execution of sale deed dated 22.08.2024.
2.	Petitioner affixed her photograph on sale deed while name mentioned as Sneha Sharma and signed as Sneha Sharma.
3.	Petitioner acted in connivance with Ravi Bansal, Lajpat Rai and Lekh Rajin cheatingcomplainant Mohan Singh.
4.	Money was transferred to petitioner's bank account by co- accused Ravi Bansal showing financial linkage.
5.	Petitioner's role revealed during interrogation of Ravi Bansal and examination of sale deed and bank record.

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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Sr. No. Antecedents of the Petitioner 1. Petitioner is involved in another FIR No. 41 dated 24.04.2025 U/s 319(2), 318(4), 338, 336(3), 340(2), 61(2) of BNS registered at Police Station Focal Point, District Ludhiana (Pending) Petitioner was nominated as an accused on 04.08.2025. Petitioner has impersonated Suman Sood by showing her owner of a property in connivance with coaccused Ravi Bansal and cheated complainant Abhinav Goel. Petitioner is absconding and yet to be arrested.

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Sr. No.	Evidence Collected Against the Petitioner
1.	Statement of complainant Mohan Singh regarding impersonation and fraudulent registry.
2.	Enquiryreport of ADCP-IV, Ludhiana.
3.	Interrogation of co-accused Ravi Bansal naming petitioner as impersonator.
4.	Sale deed dated 22.08.2024 showing photograph of petitioner with name Sneha Sharma.
5.	Bank transactions/statement showing UPI transfers from Ravi Bansal topetitioner's SBI account.
6.	Revenue record verification confirming real ownership different frompetitioner.

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Sr. No.	Custodial Interrogation of the Petitioner
1.	To ascertain full conspiracyand modus operandi.
2.	To identifyotherpersons involved in forged registry.
3.	To recover forged documents and digital evidence.
4.	To verifymoneytrail and financial transactions.
5.	To confrontpetitioner with co-accused and evidence.

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In view of the above discussion, as the offence is prima facie established and the investigation is to be taken to its logical conclusion the custodial interrogation of the petitioner is certainly required. Therefore, the present petition stands dismissed.

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

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CRM-M-11037-2026 (O & M)

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However, it is made clear that the observations made in this order are only for the purpose of deciding this bail application and the Trial Court is free to adjudicate upon the matter on the basis of the evidence led before it uninfluenced by any such observations made.

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The pending application(s), if any, shall stand disposed of

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accordingly.

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July 10, 2026 ( JASJIT SINGH BEDI) sukhpreet JUDGE Whether speaking/reasoned : Yes/No Whether reportable : Yes/No

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SUKHPREET KAUR 2026.07.13 16:30 I attest to the accuracy and integrity of this document chandigarh

Manjit Kaur v. State of Punjab

Case brief

What is this about?

What did the court decide?

Manjit Kaur v. State of Punjab

Case brief

What is this about?

What did the court decide?

What the court decided

Issues for consideration

Cases cited

Statutes considered

Procedural history

Parties & counsel

Coram

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