Forging High Court Bail Orders Strikes at the Administration of Justice; Advocate Denied Anticipatory Bail: Punjab & Haryana High Court
Case Name: Anurag Khullar @ Vishal v. U.T. Chandigarh
Date of Judgment: 15.06.2026
Citation: CRM-M-32965-2026
Bench: Hon’ble Mr. Justice Deepak Gupta
Held: The Punjab & Haryana High Court held that allegations of fabricating a forged High Court bail order and accepting money on the representation of influencing judges and public officials strike at the very foundation of the administration of justice and warrant a thorough investigation. The Court further held that being a practising advocate does not entitle an accused to any special consideration while seeking anticipatory bail, particularly where custodial interrogation is necessary for recovery and examination of digital evidence.
Summary: The petitioner, a practising advocate, sought anticipatory bail in an FIR registered under Section 318(4) of the Bharatiya Nyaya Sanhita, 2023 and Sections 8 and 12 of the Prevention of Corruption Act, 1988. The prosecution alleged that the petitioner induced the complainants to part with approximately ₹10.92 lakh by representing that he could secure bail for their relative through his influence over senior officials and members of the judiciary.
According to the prosecution, the petitioner claimed to be capable of arranging bail and demanded money towards advocates’ fees, sureties and other expenses. The complainants allegedly transferred substantial amounts through banking channels and also paid cash. It was further alleged that the petitioner showed them a purported bail order of the Punjab & Haryana High Court, although no bail application had actually been filed and the document neither bore the Court’s official seal nor related to the Bench purportedly shown in the order.
The petitioner contended that he had been professionally engaged as an advocate and that the dispute merely related to legal fees, giving rise at best to a civil dispute. He further argued that the offences under the Prevention of Corruption Act were not attracted as he was not a public servant and asserted that the case rested largely on documentary evidence, rendering custodial interrogation unnecessary.
Rejecting these submissions, the High Court observed that the status of a practising advocate neither places an individual above the law nor creates a separate standard for grant of anticipatory bail. The Court emphasized that the allegations extended far beyond a dispute over professional fees and included accusations of obtaining money by falsely claiming influence over judges and public officials, besides fabricating a forged judicial order of the High Court.
The Court noted that investigation had prima facie revealed banking transactions corroborating the transfer of substantial amounts to the petitioner and that the complainants had also produced material indicating additional cash payments. It further observed that forensic examination of electronic devices was still underway for recovery of deleted data, tracing digital footprints and identifying the devices allegedly used to prepare the forged bail order.
The High Court held that fabrication and use of a forged judicial order directly undermines public confidence in the judicial process and constitutes an allegation of exceptional gravity. Since custodial interrogation was necessary for effective recovery of electronic evidence and the prosecution had also alleged that the petitioner was evading arrest, the Court found no justification to exercise its extraordinary discretionary jurisdiction in favour of the petitioner.
Decision: The High Court dismissed the anticipatory bail petition, holding that the seriousness of the allegations, the requirement of custodial interrogation for recovery and examination of digital evidence, the alleged fabrication of a High Court bail order, and the petitioner’s alleged evasion of arrest disentitled him to the extraordinary relief of anticipatory bail.