₹2.74 Crore Land Deal Turns Criminal: P&H High Court Grants Anticipatory Bail, Calls Dispute ‘Predominantly Civil’ Amid Fraud Allegations
Case Name: Satyanarayan R. Bansal v. State of Haryana and Others
Date of Judgment: 22.04.2026
Citation: CRM-M-32968-2025
Bench: Hon’ble Mr. Justice Sanjay Vashisth
Held: The High Court held that where the dispute arises out of a property transaction supported by documentary evidence and is already subject to civil litigation, custodial interrogation is not warranted and anticipatory bail can be granted, particularly when allegations appear predominantly civil in nature.
Summary: The petitioner approached the High Court under Section 482 BNSS seeking anticipatory bail in FIR No. 0179 dated 15.05.2025 registered under Sections 120-B and 420 IPC at Police Station Bhondsi, Gurugram. The FIR was based on a complaint alleging fraudulent sale of land despite receipt of substantial consideration.
The complainant claimed that an agreement to sell dated 06.01.2009 was executed for land measuring over 104 kanals for ₹3.2 crore, out of which ₹2.74 crore had allegedly been paid, including substantial payments made to clear a bank loan. It was further alleged that despite receiving the amount, the petitioner sold part of the land to third parties in violation of a status quo order of the High Court, thereby committing fraud.
On the other hand, the petitioner contended that the dispute was purely civil in nature and that the agreement relied upon by the complainant was fabricated. It was pointed out that multiple civil proceedings, including Regular Second Appeals, were pending before the High Court concerning the same property. It was also highlighted that the Economic Offences Wing had earlier found the allegations to be baseless and civil in nature.
The High Court examined the record, including findings of the Civil Court, which had observed that the alleged agreement dated 06.01.2009 appeared to be fraudulent and had even set aside a consent decree obtained on its basis. The Court noted inconsistencies in the complainant’s stand regarding payments and observed that the controversy largely rested on documentary evidence already subject to adjudication in civil proceedings.
It was further observed that the complainant was not even a party to the pending RSA proceedings and that any rights claimed by him would depend upon the outcome of those proceedings. The Court also found no compelling necessity for custodial interrogation at this stage.
Decision: The High Court allowed the petition and granted anticipatory bail to the petitioner. It directed him to join the investigation and cooperate with the authorities. In the event of arrest, he was ordered to be released on bail subject to conditions, including furnishing bonds, surrendering passport, and seeking permission before leaving the country. The Court clarified that its observations would not affect the merits of the trial.