Punjab & Haryana High Court Denies Anticipatory Bail to Visa Agent Accused of Supplying Forged Educational Certificates; Holds Custodial Interrogation Necessary
Case Name: Kuldeep Singh v. State of Punjab
Date of Judgment: 16 January 2026
Citation: CRM-M-74090-2025
Bench: Hon’ble Mr. Justice Surya Partap Singh
Held: The Punjab and Haryana High Court held that anticipatory bail cannot be granted where specific allegations disclose the accused’s active role in preparing and supplying forged educational certificates for visa fraud, and custodial interrogation is necessary to unearth the source of forged documents and the modus operandi of the racket. The Court held that offences involving organised document fraud affecting international security and immigration processes warrant a strict approach at the pre-arrest stage.
Summary: The petition was filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking anticipatory bail in FIR No.67 dated 22.04.2025 registered under Sections 318(4), 336(2), 336(3), 338, 340 and 60 of the Bharatiya Nyaya Sanhita, 2023 at Police Station Mataur, District SAS Nagar (Mohali).
The FIR was registered on the complaint of the Overseas Criminal Investigator attached to the Regional Security Office, U.S. Embassy, New Delhi. It was alleged that certain visa agents operating in Punjab were submitting forged educational documents on the U.S. Embassy portal. During scrutiny of a non-immigrant visa application submitted by one Lovepreet Singh, a Bachelor of Arts degree purportedly issued by Chhatrapati Shahu Ji Maharaj University, Kanpur was found to be forged. During interview, the applicant admitted that the degree was fake.
During investigation, Lovepreet Singh disclosed that the forged educational certificates had been procured through the present petitioner, Kuldeep Singh. The prosecution alleged that the petitioner was instrumental in arranging forged documents for visa applicants in lieu of monetary consideration.
The petitioner contended that he was falsely implicated solely on the basis of the disclosure statement of a co-accused, that he had no criminal antecedents, and that the offence was triable by a Magistrate. It was argued that custodial interrogation was unnecessary and that he was entitled to the protection of anticipatory bail.
The State opposed the petition, contending that the petitioner played a central role in the preparation and supply of forged educational certificates, and that custodial interrogation was essential to trace the source of forged documents, identify other beneficiaries, and dismantle the larger racket.
The High Court accepted the State’s submissions and held that the allegations disclose a serious and organised offence involving preparation of forged documents for visa fraud. The Court observed that such offences have wider ramifications beyond individual cheating cases and that custodial interrogation was necessary for effective investigation.
Decision: The petition was dismissed. The Court declined to grant anticipatory bail to the petitioner. It was clarified that observations made in the order shall not be construed as an opinion on the merits of the case.