Case Name: Chirag Narula v. State of Haryana
Date of Judgment: 18 March 2026
Citation: CRM-M-12415-2026
Bench: Justice Mandeep Pannu
Held: The Punjab & Haryana High Court held that anticipatory bail cannot be granted where serious allegations of cheating and criminal conspiracy are supported by prima facie material, especially when the accused is shown to have an active role in the offence and has criminal antecedents.
Summary: The petitioner sought anticipatory bail in an FIR alleging offences of cheating, criminal breach of trust, and conspiracy in relation to a visa fraud racket. The prosecution case was that the petitioner, along with co-accused, induced the complainant to pay a substantial amount on the pretext of sending her abroad and provided a forged visa.
The petitioner contended that he was merely a salaried consultant in the immigration office run by the co-accused and had no independent role in the alleged offence. It was further argued that the amount received in his bank account had already been returned to the complainant, and therefore, no custodial interrogation was warranted.
The State opposed the plea, submitting that the petitioner actively participated in the fraudulent scheme. It was highlighted that he was associated with the co-accused in running the immigration office, was present during transactions, acted as a witness to relevant documents, and had received money from the complainant.
The Court noted that the allegations were serious and involved a well-organized scheme to cheat individuals on the pretext of arranging foreign visas. It further observed that the petitioner’s role was not merely passive but indicated active involvement in the entire transaction.
Significantly, the Court took note of the petitioner’s criminal antecedents, observing that another FIR of similar nature had been registered against him, indicating a pattern of conduct.
Considering the gravity of allegations, the active role attributed to the petitioner, and his antecedents, the Court held that the case was not fit for grant of anticipatory bail.
Decision: The High Court dismissed the anticipatory bail petition, holding that no ground for pre-arrest protection was made out.