Dismissed¶34

Chanchal v. State of Haryana

Punjab & Haryana HC16 Jul 2026CRM-M/14965/2026

Case brief

AI extract

What is this about?

Bail dismissed — murder of mother-in-law — Sections 302/201 IPC, Section 25 Arms Act 1959 — FIR No.237 dated 24.05.2024, PS Model Town, Rewari — Punjab & Haryana High Court, CRM-M-14965-2026 (O&M), decided 16.07.2026, Justice Shalini Singh Nagpal — gravity of offence outweighs about two years' custody and pending trial (09/22 witnesses examined) — incarceration alone not a ground for bail; delayed trial alone or combined with custody insufficient where gravity severe — Kalyan Chandra Sarkar Vs. Rajesh Ranjan @ Pappu Yadav 2004(2) RCR (Criminal) 254 relied upon — trial to be expedited.

What did the court decide?

No relief to the petitioner; prayer for regular bail declined. Pending miscellaneous applications, if any, stand disposed of; learned Trial Court requested to expedite the trial. ¶34

Chanchal Vs State of Haryana — Murder and Culpable Homicide | Punjab & Haryana HC (2026)

What the court decided

AI extract

Outcome

No relief to the petitioner; prayer for regular bail declined. Pending miscellaneous applications, if any, stand disposed of; learned Trial Court requested to expedite the trial.

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Issue for consideration

Whether the petitioner — in custody for about two years and facing trial for the murder of her mother-in-law under Sections 302/201 IPC and Section 25 of the Arms Act, 1959 — should be released on regular bail notwithstanding the specificity and gravity of the allegations and prosecution witnesses having supported the prosecution case.

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Court's answer

Regular bail declined: considering the nature and substance of the allegations against the petitioner, the role attributed to her and the evidence collected by the prosecution — with the complainant and the petitioner's husband having fully supported the prosecution case — the Court was not inclined to release her despite the period of incarceration.

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Ratio / Principle

The period of incarceration undergone by the petitioner, by itself, would not entitle her to bail; nor would the fact that the trial is not likely to conclude in the near future, either by itself or coupled with the period of incarceration, be sufficient to enlarge her on bail when the gravity of the alleged offence is severe — as per the Apex Court observations in Kalyan Chandra Sarkar Vs. Rajesh Ranjan @ Pappu Yadav, 2004(2) RCR (Criminal) 254.

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Key takeaways

Truth of the allegations against the petitioner and her version in defence remain to be examined by the Trial Court at the time of final hearing; meanwhile the allegations against her were characterised as specific, serious and too grave.obiter¶33
In view of the period of incarceration undergone by the petitioner, the learned Trial Court was requested to expedite the trial.obiter¶35

Detailed headnote1 paragraphs

Punjab & Haryana High Court (Shalini Singh Nagpal, J.) dismisses the first regular-bail petition of Chanchal, accused in FIR No.237 dated 24.05.2024, PS Model Town, Rewari, under Sections 302 IPC (with Sections 201 IPC and Section 25, Arms Act, 1959 added during investigation), for the murder of her mother-in-law with a kitchen knife six inches in length; post mortem records 14 injuries, 11 of them stab wounds, mostly on vital organs. Despite about two years' reported custody, only 09 of 22 prosecution witnesses examined (03 given up, 10 remaining), and the complainant-brother and the petitioner's husband having fully supported the prosecution case, the Court holds the allegations specific, serious and too grave: neither the period of incarceration alone, nor the likelihood of delayed trial alone or coupled with incarceration, entitles bail when the gravity of the offence is severe (relying on Kalyan Chandra Sarkar Vs. Rajesh Ranjan @ Pappu Yadav, 2004(2) RCR (Criminal) 254). Petition dismissed; truth of allegations and defence version left for trial; Trial Court requested to expedite the trial; pending miscellaneous applications disposed of.

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CRM-M-14965-2026 (O&M)

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IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

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213

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CRM-M-14965-2026(O&M) Reserved on : 14.07.20026 Pronounced on: 16.07.2026 Uploaded on: 16.07.2026

CHANCHAL

PETITIONER

VERSUS

STATE OF HARYANA

RESPONDENT

CORAM: HON'BLE MS. JUSTICE SHALINI SINGH NAGPAL

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Present: Mr. Aditya Sanghi, Advocate, Mr. Navtej Singh Sra, Advocate and Mr. Pradeep Bhardwaj, Advocate for the petitioner.

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Mr. Kshitij Bharti, AAG Haryana.

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Mr. Abhimanu Gupta, Advocate, Mr. Aditya Sharma, Advocate and Mr. Sanchit Garg, Advocate for the complainant.

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*** Shalini Singh Nagpal, J. (Oral)

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1 . Petitioner seeks regular bail in FIR No.237 dated 24.05.2024 under Sections 302 IPC, Police Station Model Town, Rewari, District Rewari, Haryana. Sections 201 IPC and Section 25 of the Arms Act, 1959 have been added in the FIR during investigation. This is the first petition for regular bail.

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Complainant Om Prakash, brother of the deceased made a complaint stating that his sister Maya Devi w/o Naresh Kumar, aged 59 years was residing in House No.698, Street No.10A, Rewari. His brother in law was serving in the BSF. That day on 24.05.2026 at about 01:34 A.M., his nephew Vipin Kumar telephonically informed him regarding some untoward incident upon which he reached the house of his sister and found

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HARPREET SINGH CHAUHAN 2026.07.16 17:41 I agree to specified portions of this document

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CRM-M-14965-2026 (O&M)

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the main gate locked. He scaled the wall of the house and entered inside. Chanchal, daughter-in-law of his sister had locked her room from inside and the dead body of his sister was lying in another room on the bed, in bloodsoaked condition with multiple knife injuries. At the time of the incident, his sister and her daughter-in-law were in the house. His sister had been murdered. Legal action was prayed for.

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Learned counsel for the petitioner submits that petitioner was in custody for the last two years. Two prosecution witnesses, complainantbrother of the deceased and her son, husband of the petitioner had been recorded. It is argued that in his first version to the police, complainant did not level any allegation against the petitioner. However, during the course of investigation, his supplementary statement was recorded, wherein he considerably improved upon his first version and stated that there remained quarrels between the deceased and the petitioner on domestic issues and in the night of incident also, there was some quarrel regarding food. Vipin Kumar (petitioner’s husband) in his statement under Section 161 Cr.P.C. stated about telephonic call from the petitioner about attack on his mother with a knife upon which he informed Om Prakash and Sanjeet and rushed from Delhi. It is argued that petitioner had been falsely implicated during investigation on account of matrimonial dispute with her husband and the murder was, in fact, committed by an intruder, which version was consistent with the first version according to which petitioner was locked in a room. Petitioner also suffered injuries in the incident. Om Prakash was not an eyewitness to the occurrence and had been declared hostile qua some aspects. Prosecution witnesses stood demolished in cross-examination.

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HARPREET SINGH CHAUHAN 2026.07.16 17:41 I agree to specified portions of this document

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CRM-M-14965-2026 (O&M)

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Petitioner, who had a small child and was confined for the last two years thus deserved to be released on regular bail.

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Status report by way of affidavit of Mr. Surender Sheoran, HPS, Deputy Superintendent of Police, Bawal, Rewari on behalf of the respondent-State has is on the file. Custody certificate dated 10.07.2026 has also been submitted, which is made part of the record.

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Learned State counsel has opposed the prayer for regular bail, arguing that during the course of trial, testimony of the complainant was recorded, who fully supported prosecution version. Even petitioner’s husband fully supported the case. Allegations against the petitioner were serious and specific and there was sufficient evidence collected to indicate her complicity. Trial was underway. He further submits that the injuries suffered by the petitioner resulted from the scuffle with her deceased mother-in-law with whom she had serious disputes. Recovery of knife was effected from possession of the petitioner and her own husband had deposed against her. Learned counsel for the complainant added that the post mortem report revealed 14 injuries on person of the deceased out of which 11 were stab injuries. 12 out of 22 witnesses had been examined. The child was in the custody of petitioner’s husband, who had filed for divorce after registration of FIR. It was prayed that the prayer for regular bail be declined.

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Petitioner is accused of committing murder of her mother-inlaw with a kitchen knife, six inches in length. The post mortem report records 14 injuries, 11 of them being stab wounds, mostly on vital organs. As per FIR, when complainant entered the house, petitioner was locked in one of the rooms from inside. It is nobody’s case that any articles were

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HARPREET SINGH CHAUHAN 2026.07.16 17:41 I agree to specified portions of this document

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CRM-M-14965-2026 (O&M)

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stolen from the house. Although, truth of the allegations against the petitioner and her version in defence are to be examined by the Trial Court at the time of final hearing, the fact remains that allegations against the petitioner are specific, serious and too grave. Out of 22 witnesses, prosecution has examined 09 witnesses and 03 have been given up. 10 witnesses remain to be examined. Complainant and petitioner’s husband have fully supported prosecution case. Considering the nature and substance of allegations against the petitioner, the role attributed to her, evidence collected by the prosecution against her, the Court is not inclined to release the petitioner on bail despite the period of incarceration. The fact that the petitioner has undergone certain period of incarceration, by itself, would not entitle her to bail, nor the fact that the trial is not likely to conclude in near future either by itself or coupled with the period of incarceration would be sufficient for enlarging the petitioner on bail when the gravity of the offence alleged is severe. These were the observations of the Apex Court in Kalyan

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Chandra Sarkar Vs. Rajesh Ranjan @ Pappu Yadav 2004(2) RCR (Criminal) 254 . 7. The petition accordingly, stands dismissed.

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