Allowed¶48

Leesa v. State of Punjab

Anticipatory bail – Section 482 BNSS

Punjab & Haryana HC8 May 2026CRM-M/3695/2026

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Case brief

AI extract

What is this about?

anticipatory bail; Section 482 BNSS; interim bail made absolute; FIR 315/06.12.2025 PS Kartarpur Jalandhar Rural; Sections 115(2) 118(1) 298 191(3) 190 109 Bharatiya Nyaya Sanhita 2023; female petitioner; no role attributed in FIR or supplementary statement; joined investigation; Section 482(2) BNSS conditions; Leesa v. State of Punjab; CRM-M-3695-2026; Justice Rupinderjit Chahal; Punjab & Haryana High Court.

What did the court decide?

Anticipatory bail granted: interim order dated 22.01.2026 made absolute; petitioner to continue joining investigation as and when called by the Investigating Officer and to abide by the conditions under Section 482(2) of the BNSS. ¶48

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

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the petitioner Leesa is entitled to anticipatory bail under Section 482 BNSS in case FIR No.315 dated 06.12.2025 registered at Police Station Kartarpur, in which neither the FIR nor the supplementary statement attributed any role, weapon or injury to her. +1 more

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Court's answer

Taking the cumulative effect of the recorded factors into consideration (petitioner female; no role attributed to her in the FIR; supplementary statement attributing no weapon or injury to her; nothing left to be recovered from her; custodial interrogation unlikely to produce a fruitful result; no likelihood of tampering with evidence or influencing witnesses or of non-cooperation while on interim bail), the petitioner was held entitled to interim anticipatory bail, to be released in the event of arrest on furnishing bonds to the satisfaction of the Arresting Officer.

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Ratio / Principle

In view of the statement of learned State counsel that the petitioner had joined the investigation and was no longer required for further investigation, the interim order dated 22.01.2026 passed by the Co-ordinate Bench of this Court is made absolute.

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Key takeaways

The petitioner shall continue to join investigation as and when called by the Investigating Officer and shall abide by the conditions provided under Section 482(2) of the BNSS.ratio¶48

Detailed headnote1 paragraphs

Anticipatory bail – Section 482 BNSS – CRM-M-3695-2026, decided 08.05.2026 (Rupinderjit Chahal, J.). Petitioner sought anticipatory bail in FIR No.315 dt.06.12.2025, PS Kartarpur, Distt. Jalandhar Rural, u/Ss.115(2), 118(1), 298, 191(3), 190 and 109 BNS alleging group assault on complainant Jaskaran Singh. Co-ordinate Bench (order dt.22.01.2026) granted interim anticipatory bail noting: petitioner female; no role attributed to her in FIR; supplementary statement assigned her no weapon and no injury; nothing to recover; custodial interrogation unfruitful; no tampering/influence or non-cooperation indicated. At final hearing State (on instructions of ASI Manjit Singh) conceded petitioner had joined investigation and was no longer required; interim order made absolute, petitioner to continue joining investigation and abide by S.482(2) BNSS conditions.

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CRM-M-3695-2026

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IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH

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202

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CRM-M-3695-2026 Date of decision: 08.05.2026

LEESA

….Petitioner

Versus

STATE OF PUNJAB

....Respondent

CORAM:- HON'BLE MS. JUSTICE RUPINDERJIT CHAHAL

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Present:- M r. Bhupinder Gupta, Advocate a nd M r. Aabhas Prabhakar, Advocat e f o r the petitioner.

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M r. Amrit Pal Singh Gill, DAG, P unjab.

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RUPINDERJIT CHAHAL, J. (ORAL)

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T hrough the instant petition filed under Section 482 of th e Bharatiya Na g arik Suraksha Sanhita, 2023 (f o r short “BNSS”), the petitione r seeks anticip a tory bail in case FIR No.315 d a ted 06.12.2025, under Section s 115(2), 118(1 ) , 298, 191(3), 190 and 109 of B haratiya Nyaya Sanhita, 2023 , registered at P olice Station Kartarpur, District Jalandhar Rural. 2. O n 22.01.2026, the following order was passed by the Co - ordinate Benc h of this Court: -

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“For the commission of o ff ence punishable under Section s 115(2), 118(1), 298, 191(3), 19 0 and 109 of Bharatiya Nyay a S anhita, 2023, the FIR No.315 d a ted 06.12.2025 has been lodge d i n Police Station Kartarpur, D i strict Jalandhar Rural. In th e abovementioned case, the petitioner is apprehending arrest, an d t h erefore, for the benefit of antic i patory bail she has approache d

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GURPREET 2026.05.08 14:59 I attest to the accuracy and authenticity of this document.

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CRM-M-3695-2026

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t h is Court by virtue of present petition under Section 482 o f B NSS.

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2. In nut-shell, the facts e m erging from record are that th e F IR of this case came into bei n g at the instance of 'Jaskara n S ingh', hereinafter being referre d to as 'complainant' only. It wa s s t ated by the above-named co mp lainant that on 06.12.2025 a t about 03:00 pm, when he was g o ing from home to his workplac e on motorcycle in Mohalla Ri s hi Nagar, Kartarpur locality , N aveen signaled him to stop an d when complainant stopped hi s m otorcycle, an attack was laun c hed upon him by Naveen wh o w as armed with kara, Manu Ku m ar & Sonu armed with woode n handle and Ravi, Neeraj and Pr i ya armed with stick. Accordin g t o complainant, in the above m entioned incident, he suffere d s e rious injuries.

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3. It is the case of th e prosecution that in view o f abovementioned statement, formal FIR of this case was lodge d and the investigation taken up.

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5. Notice of motion.

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6. Mr. Eklavya Darshi, D e puty Advocate General, Punja b a p pears on behalf of responden t -State. Hence service of notic e u p on the State is hereby dispensed with.

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7. Heard.

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8. It has been contended o n behalf of petitioner that a ver y d etailed statement was record e d by the Investigating Office r before lodging of FIR, wherein e ach and every detail of injurie s s u ffered by the victim was given, and in the abovementioned FIR , neither the name of the petition e r has figured, nor any role ha s been attributed to him in the co m mission of crime. According t o l e arned counsel for the petitio n er, in view of above, once n o i n jury has been attributed to the p etitioner, she is entitled for th e benefit of anticipatory bail.

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9. Per contra, the learned S tate Counsel has submitted tha t a f ter lodging of FIR, supplem e ntary statement of victim wa s r e corded, and in the supplemen t ary statement the victim state d

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GURPREET 2026.05.08 14:59 I attest to the accuracy and authenticity of this document.

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CRM-M-3695-2026

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t h at the petitioner was present o n the spot, and participated i n t h e commission of offence. How e ver, learned State Counsel ha s f a irly conceded that even in the supplementary statement, neithe r any role has been assigned to the petitioner, nor it has bee n s t ated that she was armed wit h any weapon or inflicted an y i n jury on the person of complain a nt.

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10. The record has been p e rused carefully.

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11. A perusal of the reco r d shows that there are severa l f a ctors which are required to b e taken into consideration in th e present petition at this stage. Th o se factors are:-

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i. that the petitioner, being female, deserves a lenient view ; ii. that any role has not been attributed to the petitioner i n t h e FIR;

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iii. that even in the supp l ementary statement, it has no t been stated that the petitioner w as armed with any weapon o r i n flicted any injury on the person of complainant;

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iv. that nothing is left to b e recovered from the possessio n o f petitioner;

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v. that custodial interroga t ion of the petitioner is not likel y t o produce a fruitful result;

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vi. that there is nothing o n record to show that while o n i n terim anticipatory bail, the pe t itioner is likely to tamper wit h t h e evidence or influence the wit n esses; and

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vii. that there is nothing o n record to show that while o n i n terim anticipatory bail, the petitioner will no t participate/cooperate in the inve s tigation.

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12. Taking into considera t ion the cumulative effect of al l t h e abovementioned factors, it i s hereby held that the petitione r i s entitled for interim anticipator y bail. 13. Thus, it is hereby o rd ered that in the event of he r arrest, the petitioner shall be r e leased on interim anticipator y bail on furnishing bonds to the s atisfaction of Arresting Officer . T he petitioner shall join the inv e stigation as and when called b y

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GURPREET 2026.05.08 14:59 I attest to the accuracy and authenticity of this document.

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CRM-M-3695-2026

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t h e Investigating Officer. She s hall abide by the terms an d c o nditions as envisaged under S e ction 482(2) of the BNSS, 2023. 14. List on 22.04.2026.

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15. Let status report and d etailed reply, if any, be filed b y t h e State by next date.” 3. L earned counsel for the petition e r submits that in compliance o f the order date d 22.01.2026 passed by the Co- o rdinate Bench of this Court, th e petitioner has j oined the investigation.

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L earned counsel for the State, o n instructions from ASI Manji t Singh, has su b mitted that the petitioner has j o ined the investigation and is n o longer required for further investigation.

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I n view of the statement made by learned State counsel, th e interim order dated 22.01.2026 passed by t he Co-ordinate Bench of thi s Court, is mad e absolute. The petitioner shall c ontinue to join investigation, a s and when ca l led by the Investigating Offic e r and shall also abide by th e conditions as p rovided under Section 482(2) o f the BNSS.

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(RUPINDERJIT CHAHAL) 08.05.2026 JUDGE

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Gurpreet

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i) Whether speaking/reasoned? Yes/ N o ii) Whether reportable? Yes/No

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GURPREET 2026.05.08 14:59 I attest to the accuracy and authenticity of this document.

Procedural history

How this case reached the court

AI extract

Prior proceeding
FIR No.315 dated 06.12.2025 registered at Police Station Kartarpur, District Jalandhar Rural under Sections 115(2), 118(1), 298, 191(3), 190 and 109 of Bharatiya Nyaya Sanhita, 2023 on the complaint of Jaskaran Singh, alleging an assault on him at about 03:00 pm on 06.12.2025 in Mohalla Rishi Nagar, Kartarpur by Naveen (armed with kara), Manu Kumar and Sonu (armed with wooden handle) and Ravi, Neeraj and Priya (armed with stick), in which the complainant suffered serious injuries.¶17
Prior proceeding
Instant petition filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) seeking anticipatory bail, the petitioner apprehending arrest in the abovementioned case.¶16
Prior proceeding
By order dated 22.01.2026 the Co-ordinate Bench held the petitioner entitled to interim anticipatory bail and directed that, in the event of her arrest, she be released on furnishing bonds to the satisfaction of the Arresting Officer, with liberty to the investigating agency; she was to join investigation as and when called and abide by Section 482(2) BNSS conditions; case listed for 22.04.2026 with status report/detailed reply by the State.¶41
Prior proceeding
Factors recorded on 22.01.2026 included: petitioner being female deserves a lenient view; no role attributed to her in the FIR; supplementary statement did not attribute any weapon or injury to her; nothing left to be recovered from her; custodial interrogation unlikely to produce a fruitful result; nothing to show likelihood of tampering with evidence or influencing witnesses or of non-participation/non-cooperation in investigation.¶35
Prior proceeding
On 22.01.2026 learned State Counsel fairly conceded that even in the supplementary statement no role was assigned to the petitioner, nor was she stated to be armed with any weapon or to have inflicted any injury on the complainant, though the victim asserted her presence and participation on the spot.¶32
Prior proceeding
In compliance with the order dated 22.01.2026, learned counsel for the petitioner submitted that the petitioner had joined the investigation.¶46
Prior proceeding
At the final hearing, learned counsel for the State, on instructions from ASI Manjit Singh, submitted that the petitioner had joined the investigation and was no longer required for further investigation.¶47

Leesa v. State of Punjab

Case brief

What is this about?

What did the court decide?

Leesa v. State of Punjab

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

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Case details

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