Punjab & Haryana High Court Denies Regular Bail to Advocate Accused of Demanding Bribe to Influence Judicial Outcome; Holds Allegations Strike at Institutional Integrity
Case Name: Jatin Salwan v. Central Bureau of Investigation
Date of Judgment: 02 February 2026
Citation: CRM-M-51882-2025
Bench: Hon’ble Mr. Justice Sumeet Goel
Held: The Punjab and Haryana High Court held that regular bail cannot be granted in a corruption case where prima facie material indicates demand and acceptance of illegal gratification by an advocate by claiming influence over a judicial officer. The Court held that such allegations, if true, undermine the sanctity of the judiciary and public confidence in the justice delivery system, warranting a stringent approach at the stage of bail.
Summary: The petition was filed under Section 439 CrPC seeking regular bail in FIR No. RC0052025A0015 dated 14.08.2025 registered under Section 61(2) of the Bharatiya Nyaya Sanhita, 2023 read with Section 7A of the Prevention of Corruption Act, 1988 at Police Station CBI, ACB, Chandigarh. The petitioner is an advocate practicing at the Punjab and Haryana High Court.
The FIR was registered on the basis of a written complaint dated 13.08.2025 submitted by the complainant Harsimranjit Singh, alleging that the petitioner demanded illegal gratification of ₹30,00,000 for securing a favourable judicial order in a divorce matter pending before the courts at Bathinda, Punjab. It was alleged that the petitioner claimed to exercise personal influence over a judicial officer and insisted that the bribe amount was non-negotiable.
The complaint was verified by the CBI through recorded telephonic conversations on 13.08.2025 and 14.08.2025, which prima facie substantiated the demand of illegal gratification. Upon completion of verification, the FIR was registered and a trap was laid on the same day. During the trap proceedings, co-accused Satnam Singh, allegedly acting at the behest of the petitioner, accepted ₹4,00,000 as part payment of the demanded bribe. The conversation during the transaction was recorded, and the tainted amount was recovered. The petitioner was arrested on 14.08.2025 and remanded to judicial custody on 15.08.2025. His earlier application for regular bail before the Special Judge, CBI, Chandigarh was dismissed on 01.09.2025.
Before the High Court, the petitioner contended that he was falsely implicated, that he was neither a public servant nor capable of influencing the judicial officer concerned, and that the alleged demand was misconstrued from professional fees quoted for conducting litigation. It was further argued that the complaint and FIR suffered from inconsistencies, that custodial interrogation was no longer required, and that the petitioner, aged about 70 years, was suffering from serious cardiac ailments.
The CBI opposed the petition, contending that the allegations were grave, that the demand was duly verified prior to registration of the FIR, and that recorded conversations and trap proceedings prima facie established demand and acceptance of illegal gratification. It was submitted that Section 7A of the Prevention of Corruption Act squarely applies to any person who accepts or obtains undue advantage to influence a public servant, and that the petitioner’s age or professional standing could not dilute the seriousness of the offence.
The Court undertook an extensive discussion on the impact of corruption on institutional integrity, particularly when allegations relate to misuse of influence in the judicial process. Relying on Supreme Court precedents including Niranjan Hemchandra Sashittal v. State of Maharashtra and State through CBI v. Amarmani Tripathi, the Court reiterated that bail discretion must be exercised cautiously in corruption cases. The Court held that the prima facie material on record, the manner of commission of the alleged offence, its potential impact on public confidence, and the petitioner’s involvement in another criminal case disentitled him from the concession of regular bail at this stage.
Decision: The bail petition was dismissed. Liberty was reserved in favour of the petitioner to apply for regular bail afresh before the Special Court after examination of the complainant and the victim witnesses.