Dismissed¶29

Parminder Singh v. State of Punjab

Punjab & Haryana HC25 May 2026CRM-M/19708/2026

Case brief

AI extract

What is this about?

CRM-M-19708-2026; Parminder Singh v. State of Punjab; anticipatory bail refused; Section 482 BNSS; Sections 316(5) and 318(4) BNS; FIR No. 183 dated 28.10.2025; Police Station Dirba; District Sangrur; Cooperative Marketing Society Dirba; embezzlement Rs. 16,39,456; damaged/deteriorated stock Rs. 8,84,361.56; fake sales; custodial interrogation required; extraordinary power to be exercised sparingly; Additional Sessions Judge Sangrur order dated 14.11.2025; Manisha Batra, J.; decided 25.05.2026; petition dismissed.

What did the court decide?

For the purpose of conducting a proper investigation into the alleged embezzlement and damage to society stock, custodial interrogation of the petitioner is required. ¶26

Parminder Singh Vs State of Punjab — Cheating and Forgery | Punjab & Haryana HC (2026)

What the court decided

AI extract

Outcome

Dismissed

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Issue for consideration

Whether the petitioner, apprehending arrest in FIR No. 183 dated 28.10.2025 registered under Sections 316(5) and 318(4) of the Bharatiya Nyaya Sanhita, 2023, is entitled to anticipatory bail.

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Court's answer

For the purpose of conducting a proper investigation into the alleged embezzlement and damage to society stock, custodial interrogation of the petitioner is required.

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Ratio / Principle

The powers of anticipatory bail are extraordinary and are to be exercised sparingly and only in exceptional circumstances; the Court must be circumspect and grant pre-arrest bail only when convinced that exceptional circumstances exist.

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Key takeaways

Denial of custodial interrogation to the Investigating Agency would leave many glaring loopholes and gaps, thereby adversely affecting the investigation.ratio¶29
This Court is not inclined to grant the concession of pre-arrest bail to the petitioner.ratio¶29
Observations made in the judgment shall not be construed as an expression of opinion on the merits of the case.obiter

Detailed headnote1 paragraphs

High Court of Punjab & Haryana (Manisha Batra, J., oral) dismisses a Section 482 BNSS anticipatory-bail petition filed by Parminder Singh, previously posted as Manager in Cooperative Marketing Society, Dirba, who is arraigned in FIR No. 183 dated 28.10.2025 of Police Station Dirba, District Sangrur, under Sections 316(5) and 318(4) of the Bharatiya Nyaya Sanhita, 2023, for alleged embezzlement of Rs. 16,39,456/- and negligent damage to society stock worth Rs. 8,84,361.56/-; his earlier anticipatory-bail application had been dismissed by the Additional Sessions Judge, Sangrur, vide order dated 14.11.2025. Holding that custodial interrogation of the petitioner was required for a proper investigation, that the power of anticipatory bail is extraordinary and must be exercised sparingly in exceptional circumstances, and that denial of custodial interrogation would leave glaring loopholes and gaps adversely affecting the investigation, the Court declined pre-arrest bail and dismissed the petition, clarifying that its observations were not an expression of opinion on the merits of the case.

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CRM-M-19708-2026 -1-

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IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

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204 CRM-M-19708-2026 Date of decision: 25^th May, 2026

Parminder Singh

...Petitioner

Versus

State of Punjab

...Respondent

CORAM: HON'BLE MRS. JUSTICE MANISHA BATRA

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Present: Mr. P.S. Sekhon, Senior Advocate with

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Mr. Kaushal Chahal, Advocate for the petitioner.

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Ms. Sakshi Bakshi, Assistant Advocate General, Punjab.

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MANISHA BATRA, J (ORAL):-

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The present petition has been filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (for short ‘BNSS’) by the petitioner seeking grant of anticipatory bail in case bearing FIR No. 183 dated 28.10.2025 registered under Sections 316(5) and 318(4) of Bharatiya Nyaya Sanhita, 2023 (for short ‘BNS’) at Police Station Dirba, District Sangrur.

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The aforementioned FIR was registered on the basis of a complaint received from the office of Assistant Registrar, Cooperative Societies, Sunam Udham Singh Wala, alleging therein that the petitioner, who was previously posted as Manager in Cooperative Marketing Society, Dirba, had embezzled an amount of ₹16,39,456/-. An inquiry had been conducted by the Divisional Inspector, Cooperative Societies and a report was submitted as

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PARVEEN SHARMA 2026.05.27 14:17 I attest to the accuracy and integrity of this document

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CRM-M-19708-2026 -2-

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per which, stock worth ₹8,84,361.56/- as kept in the stock of the society, under the charge of the petitioner, was found to be in a damaged and deteriorated condition due to negligence on the part of the petitioner. That apart, the petitioner had shown fake sales and a huge quantity of stock as reflected in the stock register/report was not found to be available. The total value of the said stock was ₹16,39,456/-. On the basis of the said complaint and inquiry report, FIR was registered. Investigation proceedings have been initiated and are underway. Apprehending his arrest, the petitioner moved an application for grant of anticipatory bail, which was dismissed by the Court of learned Additional Sessions Judge, Sangrur, vide order dated 14.11.2025.

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It is argued by learned counsel for the petitioner that he has been falsely implicated in the present case. Stock lying with Cooperative Societies, Sullar and Mehalan, was under the charge of the petitioner but the same has not been taken into consideration while making calculations. Apart from this, the petitioner is ready to provide complete details and records regarding purchase and sale of articles and stocks. It has also been contended that one Robin Goyal, who was posted as Assistant Registrar, Cooperative Societies, Sunam, and who used to collect commission from the company, had exploited the petitioner. It is argued that the petitioner did not commit any offence of cheating or embezzlement. No monetary benefit has been established to have been taken by him. He was not even having regular charge of the Dirba Marketing Cooperative Society and was having only additional charge. The allegations levelled against him are vague and baseless. He is ready to join the

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PARVEEN SHARMA 2026.05.27 14:17 I attest to the accuracy and integrity of this document

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CRM-M-19708-2026 -3-

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investigation. His custodial interrogation is not required. No recovery is to be effected from him. The case is based upon documentary evidence. It is, therefore, argued that the petition deserves to be allowed.

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Per contra , learned State counsel has argued that the allegations against the petitioner are serious in nature. For the purpose of conducting proper investigation, custodial interrogation of the petitioner is must. The petitioner has failed to make out any extraordinary or exceptional circumstance for grant of bail. Therefore, it is argued that the petitioner does not deserve the concession of anticipatory bail.

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This Court has heard the rival submissions made by learned counsel for the parties at considerable length.

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The petitioner is alleged to have caused wrongful loss to the Cooperative Societies by causing damage to stock due to his negligence and by embezzling a huge quantity of the stock of the Society under his charge. For the purpose of conducting a proper investigation, custodial interrogation of the petitioner is required. The powers of anticipatory bail are extra ordinary and the same are to be exercised sparingly and in exceptional circumstances. The Court must be circumspect while exercising such power for grant of anticipatory bail and it should not be granted as a matter of rule and has to be granted only when the Court is convinced that exceptional circumstances exist to resort to that extra ordinary remedy. It is well settled that anticipatory bail to an accused can be granted in exceptional circumstances only as a person

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PARVEEN SHARMA 2026.05.27 14:17 I attest to the accuracy and integrity of this document

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CRM-M-19708-2026 -4-

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couched in comparative safety of pre-arrest bail would certainly not disclose all the facts within his knowledge. In case custodial interrogation of the petitioner is denied to the Investigating Agency, that shall leave many glaring loopholes and gaps, thereby adversely affecting the investigation. In view of the above discussed facts and circumstances, this Court is not inclined to grant concession of pre-arrest bail to the petitioner. Accordingly, the petition is

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dismissed.

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