Case Name: Joginder Sharma v. State of Haryana and Baldev Kaur v. State of Haryana
Date of Judgment: 26 May 2026
Citation: CRM-M-10902-2026 and CRM-M-13239-2026
Bench: Justice Jasjit Singh Bedi
Held: The Punjab & Haryana High Court refused anticipatory bail to a serving revenue officer and a landowner accused in a large-scale conspiracy involving the alleged illegal sale of land linked to the Pearl Group (PGF/PACL). The Court held that the material collected during investigation, including the financial trail, revenue records, witness statements, and allegations of manipulation of revenue entries to facilitate prohibited land transactions, disclosed a strong prima facie case. In corruption-related offences involving abuse of public office and organized economic crime, anticipatory bail can be granted only in exceptional circumstances, which were absent in the present case.
Summary: The petitions arose out of FIR No. 3 dated 30 January 2026 registered by the State Vigilance and Anti-Corruption Bureau, Panchkula, under provisions of the Prevention of Corruption Act and the Bharatiya Nyaya Sanhita. The allegations centered around the sale of land situated in Village Shahpur, Tehsil Raipur Rani, Panchkula, which was allegedly subject to restrictions flowing from proceedings concerning the Pearl Group entities, namely PGF Ltd. and PACL Ltd.
The prosecution case traced the history of the land to acquisitions made by PGF Ltd. and associated entities. Following investigations by the CBI and directions issued by the Supreme Court in matters concerning the Pearl Group investment scam, restrictions were imposed on transfer and alienation of properties connected with PGF Ltd., PACL Ltd. and their associate entities. Revenue authorities had recorded a red-ink entry in the revenue record to prevent any unauthorized sale or transfer of such properties without approval of the competent committee constituted under orders of the Supreme Court.
According to the Vigilance Bureau, despite these restrictions, the red-ink entry was removed from the revenue record in September 2025. Shortly thereafter, Baldev Kaur sold approximately 141 kanals of land to Naveen for ₹1 crore. Within weeks, the same land was allegedly sold onward through four separate sale deeds for a combined consideration of ₹5.80 crore. The investigating agency alleged that the transactions formed part of a planned conspiracy to monetize land which could not legally be alienated.
The Court noted the prosecution’s allegations that Joginder Sharma, a revenue officer, played a central role in the conspiracy. Investigation allegedly revealed that the purchasers had been interacting with him throughout the transaction and that substantial sums had flowed through accounts connected with his relatives. The prosecution also relied upon witness statements, telephonic conversations, banking records and call detail records to contend that he actively facilitated the transactions.
Particular significance was attached to the financial trail. The Court recorded allegations that although Baldev Kaur executed a sale deed for ₹1 crore, she ultimately received only about ₹60 lakh after funds were routed through intermediaries. Thereafter, the land was allegedly resold for ₹5.80 crore. Investigation further suggested that entities connected to the petitioner’s family received substantial amounts linked to the subsequent transactions. The Court observed that these circumstances prima facie supported the prosecution’s theory of a larger conspiracy.
The Court also referred to earlier correspondence exchanged with the Justice R.M. Lodha Committee concerning sale restrictions on PACL/PGF-linked properties. According to the State, Joginder Sharma had prior knowledge of the restrictions and the procedure required for obtaining permission before alienation of such land. Despite this knowledge, the prohibited transaction was allegedly facilitated through manipulation of revenue records and misuse of official position.
Baldev Kaur argued that she was a 76-year-old illiterate widow who had been misled by property dealers and revenue officials. Joginder Sharma contended that he was not named in the FIR, that there was no recovery of bribe money from him, and that the case rested largely on documentary evidence. Both petitioners sought protection from arrest on these grounds.
Rejecting the submissions, the Court emphasized that corruption-related offences and organized economic crimes have far-reaching consequences and require a strict approach while considering anticipatory bail. Relying upon recent Supreme Court precedents, the Court reiterated that absence of immediate custodial interrogation is not by itself a ground for grant of anticipatory bail where a strong prima facie case exists.
The Court ultimately concluded that the material collected during investigation disclosed deliberate removal of protective revenue entries, illegal alienation of restricted land, suspicious movement of funds, and a coordinated conspiracy involving multiple actors. Given the seriousness of the allegations and the stage of investigation, no case for anticipatory bail was made out.
Decision: The Punjab & Haryana High Court dismissed both petitions and declined anticipatory bail to Joginder Sharma and Baldev Kaur. The Court held that the allegations revealed a prima facie case of corruption, conspiracy, manipulation of revenue records, and illegal sale of restricted land linked to the Pearl Group investigations. Considering the gravity of the accusations and the material collected during investigation, the petitioners were not entitled to the extraordinary relief of anticipatory bail.