Punjab & Haryana High Court Declines Anticipatory Bail in Alleged Embezzlement Case; Holds Custodial Interrogation Necessary in Serious Economic Offences

Case Name: Baljeet Singh v. State of Punjab
Date of Judgment: 11 December 2025
Citation: CRM-M-63512-2025
Bench: Hon’ble Mr. Justice Sumeet Goel

Held: The Punjab and Haryana High Court declined to grant anticipatory bail to the petitioner accused of involvement in a conspiracy relating to misappropriation of funds from a fruit trading business, holding that serious allegations of economic offence, supported by preliminary material, warranted custodial interrogation. The Court held that anticipatory bail is an extraordinary remedy and cannot be granted as a matter of right, particularly where investigation is at a nascent stage and tracing of funds and conspirators is required.

Summary: The case arose from allegations of large-scale embezzlement from a fruit trading business operated by the complainant at Amritsar. It was alleged that Manjit Singh, who was entrusted with managing business affairs, misappropriated money collected from buyers and failed to deposit the same into the firm’s account. Upon verification of transactions with buyers, the complainant discovered diversion of funds and alleged that the fraudulent activity was carried out in connivance with the petitioner Baljeet Singh and other associates, with portions of the embezzled amount being routed into their bank accounts.

An FIR was registered for offences including criminal breach of trust and criminal conspiracy. The petitioner sought anticipatory bail contending that he was falsely implicated merely on account of his relationship with the main accused, that no entrustment of property was made to him, and that no recovery had been effected from his possession. It was also argued that the dispute was essentially civil in nature and that custodial interrogation was unnecessary.

The State opposed the petition, asserting that the FIR contained specific allegations indicating the petitioner’s active role in the conspiracy and that investigation had revealed financial transactions linking him to the misappropriated funds. It was submitted that custodial interrogation was required to trace the flow of money, identify other beneficiaries, and unearth the full extent of the conspiracy.

The Court noted that the FIR was not a vague narration but disclosed a detailed sequence of events supported by preliminary material. It held that the petitioner’s plea of lack of entrustment and false implication could not be conclusively examined at the anticipatory bail stage, particularly when allegations related to criminal conspiracy and economic offences.

Decision: The High Court dismissed the petition for anticipatory bail, holding that the gravity of the allegations, the nature of the offence, and the requirement of custodial interrogation outweighed the petitioner’s claim for pre-arrest protection. The Court clarified that nothing observed would be construed as an opinion on the merits of the case.