Allowed¶36

Mangi Lal v. State of Haryana

Punjab & Haryana HC29 May 2026CRM-M/21662/2026

Case brief

AI extract

What is this about?

Punjab & Haryana High Court, CRM-M-21662-2026, decided 29.05.2026 by Sanjay Vashisth, J. (Oral): regular bail under Section 483 BNSS allowed in NDPS case FIR 0590/2025 (Ss. 15(c)/61/85), PS Azad Nagar Hisar; 60 kg poppy straw recovery held marginally above non-commercial quantity; implication rests mainly on co-accused Vijay Pal's disclosure statement and untested CDRs; custody ~4 months; release on bail/surety bonds; no merits commented; trial court to decide independently.

What did the court decide?

Petitioner ordered to be released on regular bail subject to furnishing bail/surety bonds to the satisfaction of the learned trial Court/Chief Judicial Magistrate/Illaqa Magistrate/Duty Magistrate concerned, if not required in any other case; petition stands disposed of. ¶36

Mangi Lal Vs State of Haryana — Narcotics (NDPS) | Punjab & Haryana HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether petitioner Mangi Lal, implicated in FIR No.0590/2025 (Sections 15(c)/61/85 NDPS Act) primarily through the disclosure statement of co-accused Vijay Pal and call detail records, is entitled to regular bail under Section 483 BNSS. +1 more

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Court's answer

Without commenting on the merits, the Court allowed the petition and ordered the petitioner's release on bail subject to furnishing bail/surety bonds, if not required in any other case.

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Ratio / Principle

The alleged recovery of contraband is only marginally above the maximum prescribed for non-commercial quantity.

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Key takeaways

The explanation in the status report regarding the petitioner's alleged connectivity with main accused Vijay Pal is a matter requiring detailed appreciation during trial after the entire evidence is led before the trial Court.ratio¶30
The relevancy and evidentiary value of the call detail records is yet to be finally adjudicated.ratio¶35
Nothing recorded in the discussion shall be construed as an expression of opinion on the facts; the trial Court is to decide independently on the record, as expeditiously as possible.

Detailed headnote1 paragraphs

Regular bail — NDPS Act, Ss. 15(c)/61/85 — petition under S. 483 BNSS — FIR No.0590 dated 01.08.2025, PS Azad Nagar, Hisar — 60 kg doda post (poppy straw) recovered from co-accused Vijay Pal; petitioner named in his disclosure statement as supplier, arrested 21.01.2026, supplementary challan filed — recovery held only marginally above the non-commercial ceiling; petitioner's connectivity with co-accused (CDRs/SMS) and disclosure statement a matter for trial appreciation; evidentiary value of CDRs yet to be adjudicated — custody about four months — bail granted without commenting on merits, subject to surety bonds; observations not to be treated as expression of opinion on facts; trial Court to take independent view expeditiously.

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CRM-M-21662-2026

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IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

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204 CRM-M-21662-2026 Decided on :29.05.2026

Mangi Lal

. . . Petitioner(s)

Versus

State of Haryana . . . Respondent(s)

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CORAM: HON'BLE MR. JUSTICE SANJAY VASHISTH Present: Mr. Raman Chawla, Advocate for the petitioner.

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Mr. Amish Sharma, Asst. A.G., Haryana.

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SANJAY VASHISTH, J. (Oral)

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P resent petition has been filed under Section 483 of the BNSS, seeking regular bail in case FIR No.0590 dated 01.08.2025, under Sections 15(c)/61/85 of NDPS Act, registered at Police Station Azad Nagar Hisar, District Hisar.

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2 . C ase of the prosecution is that on 01.08.2025, on the basis of secret information, police party headed by ASI Sunil Kumar apprehended accused Vijay Pal while he was travelling in a Creta car bearing registration No. HR29-AK-2215. From his possession, 60 kg of doda post (poppy straw) was recovered.

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After registration of the FIR, investigation proceeded. During the course of investigation, accused-Vijay Pal allegedly made disclosure statement naming present petitioner-Mangi Lal, as his coaccused being supplier of the recovered contraband. Subsequently, after the arrest of the petitioner on 21.01.2026, investigation was completed

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RASHMI 2026.05.29 19:38 I attest to the accuracy and integrity of this document

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CRM-M-21662-2026

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and supplementary challan was presented against both accused persons, including the petitioner.

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Learned counsel for the petitioner submits that petitioner has been implicated solely on the basis of the disclosure statement of the main accused-Vijay Pal, from whom 60 kg of doda post was recovered. It is further contended that except for the disclosure statement, no other incriminating evidence has been collected by the Investigating Officer against the petitioner.

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With regard to the allegation that petitioner had contacted accused-Vijay Pal through mobile phone, learned counsel submits that the call detail records and SMS records pertain to a period prior to the alleged recovery. It is further submitted that petitioner’s mobile phone was lost in April 2025, regarding which a complaint dated 11.04.2025 (Annexure P-2) was also made to the SHO, Police Station Mojapur.

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Learned counsel further submits that petitioner is in custody since 21.01.2026, i.e., for about four months and eight days, and trial is not likely to conclude in near future. In these circumstances, learned counsel for the petitioner prays for grant of regular bail to the petitioner. 5. On the other hand, learned State counsel has filed the custody certificate in Court today, which is taken on record. Office to tag the same at appropriate place. A copy thereof has been handed over to the learned counsel for the petitioner.

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Learned State counsel, while opposing the bail, submits that the recovery involved in the present case is of commercial quantity, i.e., 60 kg of doda post (poppy straw), which is much beyond the commercial

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RASHMI 2026.05.29 19:38 I attest to the accuracy and integrity of this document

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CRM-M-21662-2026

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threshold prescribed under the NDPS Act. It is further submitted that investigation has revealed sufficient incriminating material against the petitioner in the form of call detail records (CDRs) and messages exchanged between the petitioner and co-accused-Vijay Pal, which establish their connection and involvement in the illicit supply chain.

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It is further contended that the recovered contraband was allegedly supplied by the petitioner to accused-Vijay Pal for a sale consideration of 1,80,000/-. Allegations, therefore, disclose a well-₹ organized illicit trafficking network involving the petitioner. In these circumstances, it is submitted that the petitioner does not deserve the concession of bail and prays for dismissal of present petition.

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6 . I have heard learned counsel for the parties and have carefully perused the paper-book, along with the documents appended thereto.

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7 . Alleged recovery of contraband in the present case is only marginally above the maximum prescribed for non-commercial quantity. The explanation furnished in the status report filed by the respondent/State that there is sufficient evidence against the petitioner, showing his alleged connectivity with main accused-Vijay Pal, from whom 60 kg of doda post was recovered, is a matter which would require detailed appreciation during the course of trial after the entire evidence is led before the learned trial Court.

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8 . Petitioner is in custody for a period of last about four months and six days and his involvement in the present case, at this stage, is stated to be primarily based on the disclosure statement of the co-

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RASHMI 2026.05.29 19:38 I attest to the accuracy and integrity of this document

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CRM-M-21662-2026

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accused. The relevancy and evidentiary value of the call detail records is yet to be finally adjudicated.

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Thus, without commenting on the merits of the case, this Court deems it appropriate to allow the present petition. Petitioner is ordered to be released on bail, subject to his furnishing bail/surety bonds to the satisfaction of the learned trial Court/ Chief Judicial Magistrate/Illaqa Magistrate/ Duty Magistrate concerned, if not required in any other case.

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Any of the discussion done and recorded hereabove, shall not be construed as an expression of opinion on the facts of the case. Therefore, trial Court is expected to decide the case by taking an independent view, on the basis of evidence available on record, as expeditiously as possible in accordance with law.

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10. Petition stands disposed of.

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(SANJAY VASHISTH) JUDGE

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29.05.2026 Rashmi

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Whether speaking/reasoned: Yes/No Whether Reportable: Yes/No

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RASHMI 2026.05.29 19:38 I attest to the accuracy and integrity of this document

Mangi Lal v. State of Haryana

Case brief

What is this about?

What did the court decide?

Mangi Lal v. State of Haryana

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

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Statutes considered

Procedural history

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