HDFC Relationship Manager Accused of ₹9 Crore Fraud: Punjab & Haryana High Court Refuses Anticipatory Bail in Fiduciary Breach Case
Case Name: Saloni Goyal v. State of Haryana
Date of Judgment: 16 February 2026
Citation: CRM-M-33767-2025
Bench: Hon’ble Mrs. Justice Manisha Batra
Held: The Punjab and Haryana High Court held that anticipatory bail can be granted only in exceptional circumstances, and where serious allegations of large-scale financial fraud involving breach of fiduciary duty are made, custodial interrogation may be necessary for effective investigation. The Court held that at a nascent stage of investigation, and in the absence of extraordinary circumstances, pre-arrest bail cannot be granted, particularly when the accused is alleged to have masterminded the conspiracy and misappropriated substantial funds.
Summary: The petition was filed under Section 438 Cr.P.C. seeking pre-arrest bail in FIR No. 296 dated 28.08.2024 registered under Sections 406, 420, 409, 506 and 120-B IPC at Police Station Civil Lines, Jind, District Jind .
The FIR was lodged on the complaint of Rajender Singh, who alleged that he had opened multiple bank accounts at the HUDA Market Branch of HDFC Bank in the name of himself and his family members and had also availed an agricultural loan. The petitioner, who was working as a relationship manager with the bank, was alleged to have taken advantage of her position of trust.
It was alleged that by instilling confidence in the complainant, who was also her landlord, the petitioner had taken possession of passbooks, cheque books, FDRs and other documents belonging to him and his family members. The complainant later discovered that an amount of approximately ₹9 Crores had been transferred from his and his family members’ accounts in connivance with the petitioner’s family members and certain bank officials. It was further alleged that ₹4,50,93,000/- had been transferred directly to the petitioner’s own account and other amounts were routed to accounts of her husband, brother and uncle .
The petitioner contended that she had been falsely implicated and that the complainant himself had availed loans and carried out numerous transactions. It was argued that she became relationship manager only in April 2022 and that four co-accused had already been granted bail. It was further submitted that the case was based on documentary evidence already in possession of the Investigating Agency and that custodial interrogation was not required.
The State opposed the petition, submitting that the petitioner was the mastermind who had misused her fiduciary position by opening bank accounts without the complainant’s knowledge, retaining cheque books and documents, and facilitating wrongful transfers of huge sums. It was argued that custodial interrogation was essential for a thorough investigation.
The Court observed that the allegations against the petitioner were serious in nature and involved cheating and criminal conspiracy resulting in wrongful loss of a substantial amount. The investigation was still at a nascent stage. The Court held that anticipatory bail is to be granted only in exceptional circumstances and that a person protected by pre-arrest bail may not disclose all material facts within her knowledge. Denial of custodial interrogation at this stage could adversely affect the investigation and leave significant gaps .
Finding no exceptional or extraordinary circumstance warranting the grant of anticipatory bail, the Court declined to exercise its discretion in favour of the petitioner.
Decision: The petition for anticipatory bail was dismissed. The Court clarified that observations made in the order shall not influence the merits of the case at trial .