Multiple FIRs, Digital Money Trail & No Licence: Punjab & Haryana High Court Denies Anticipatory Bail in Immigration Fraud Case
Case Name: Manpreet Kaur @ Muskan v. State of Punjab and Another
Date of Judgment: 13 February 2026
Citation: CRM-M-3013-2026
Bench: Hon’ble Ms. Justice Mandeep Pannu
Held: The Punjab and Haryana High Court held that anticipatory bail cannot be granted where specific and supported allegations disclose prima facie dishonest inducement, digital transfer of funds into the accused’s account, and active participation in immigration-related fraud. Partial repayment of money does not negate criminal intent at inception. Custodial interrogation may be necessary in cases involving systematic modus operandi and multiple FIRs.
Summary: The petitioner sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 in FIR No. 174 dated 20.08.2024 registered under Section 420 IPC and Section 24 of the Immigration Act at Police Station Sadar Ludhiana.
The FIR was lodged on the complaint of Rajni Bala, who alleged that the petitioner induced her to travel to England on a five-year work permit visa and, on that pretext, received ₹1,12,500 through digital transactions on various dates. The amount was transferred via Google Pay and credited into the petitioner’s account. The petitioner allegedly collected the complainant’s passport copy, Aadhaar card, photographs and other documents, and also got her medical examination conducted. Thereafter, she neither arranged the visa nor returned the money and stopped responding to calls.
The status report revealed that five other FIRs of similar nature were registered against the petitioner in Ludhiana, pertaining to immigration-related cheating.
The petitioner contended that she was falsely implicated, that her husband ran the immigration business, and that she merely received money on his behalf. It was argued that essential ingredients of Section 420 IPC were not attracted and that the dispute was civil in nature. She further claimed to have refunded ₹1,00,000, demonstrating bona fides, and argued that no custodial interrogation was required.
The State opposed the petition, submitting that the petitioner projected herself as competent to arrange a visa, received the entire amount directly in her account, retained the complainant’s documents, and actively controlled the process. It was further submitted that she was engaged in immigration-related activities without licence and that custodial interrogation was necessary to uncover a wider conspiracy and trace other victims.
Upon perusal of the FIR and material collected during investigation, the Court observed that the payment trail was supported by documentary and electronic evidence. The conduct attributed to the petitioner—receiving money, retaining documents, failing to secure visa, and thereafter avoiding communication—prima facie indicated dishonest intention from inception.
The Court further noted the existence of other similar FIRs suggesting a pattern of conduct. It held that partial repayment of ₹1,00,000 would not dilute the gravity of allegations where the offence of cheating hinges upon fraudulent inducement at the very beginning.
Considering the seriousness of allegations, the specific role attributed, and necessity of custodial interrogation for effective investigation, the Court found no ground to grant anticipatory bail.
Decision: The petition was dismissed. The Court held that it was not a fit case for grant of anticipatory bail.