Punjab & Haryana High Court Declines Cancellation of Bail; Finds No Material Showing Misuse or Supervening Circumstances

Case Name: Mohd. Jakir vs. State of Haryana and Another
Date of Judgment: 13 November 2025
Citation: CRM-M-60803-2025
Bench: Hon’ble Mr. Justice Sumeet Goel

Held: The Punjab and Haryana High Court dismissed the petition seeking cancellation of regular bail granted to the accused, holding that the petitioner failed to demonstrate any misuse of the bail concession or the existence of supervening circumstances warranting cancellation. The Court reiterated that cancellation of bail cannot be sought merely by repeating allegations already considered while granting bail, and that seriousness of the offence alone is not sufficient to recall a bail order once liberty has been granted. It emphasized that cancellation requires credible material showing intimidation, absconding, tampering with evidence, or violation of bail conditions.

Summary: The petitioner sought cancellation of regular bail granted to respondent No.2, alleging forgery of a Nikahnama and subsequent threats to coerce a compromise. The FIR alleged fabrication of signatures and use of a forged marriage document. The State placed on record the investigation steps, including disclosure statements, recovery of the allegedly forged Nikahnama, and pending arrest of co-accused. The Court examined the distinction between cancellation of bail and setting aside a bail order, referring to its earlier decision in Dinesh Madan vs. State of Haryana, noting that cancellation is justified only when liberty has been abused or new facts emerge after grant of bail. The Court observed that except for generalized allegations of threats, no complaint, witness statement, call record, or supporting material was produced to substantiate misuse. It further noted that the case was still under investigation and no charge had yet been framed.

Decision: The petition was dismissed. The Court held that the order of the Additional Sessions Judge granting bail was a reasoned speaking order based on assessment of facts, custody duration and absence of criminal antecedents, and there was no perversity or illegality warranting interference. Finding no violation of conditions and no supervening circumstance, the Court declined to cancel bail. It clarified that nothing in the order shall influence the merits of trial and all pending applications stood disposed of.