P&H High Court Denies Bail in Tramadol Commercial-Quantity Case; Rejects Medical-Hardship Plea

Case Name: Varinder Singh @ Raju vs. State of Punjab
Date of Judgment: 10 November 2025
Citation: CRM-M-26984-2025
Bench: Hon’ble Mrs. Justice Manisha Batra

Held: The Punjab & Haryana High Court refused bail to the petitioner, who faced prosecution under Section 22(C) NDPS Act for alleged possession of commercial quantity of Tramadol tablets. The Court found that the medical report from AIIMS Bathinda showed only post-operative changes and stable condition, with the petitioner able to perform daily activities. It held that Section 37 NDPS Act barred bail because the quantity was commercial and no exceptional circumstance existed to override the statutory embargo. The Court noted that the petitioner had availed interim bail earlier and had surrendered later, but this did not establish any change in circumstances warranting regular bail.

Summary: The FIR alleged that the police apprehended the petitioner and a co-accused while they were searching two polythene bags. The police recovered 700 strips of Tramadol tablets from them and 880 tablets from the co-accused. The petitioner argued false implication and claimed that he consumed tramadol for a spinal condition. He relied on his lumbar spine surgery of 2023 and complained of leg pain. The State produced AIIMS medical records which showed stable condition and no emergent complication. The Court reviewed the allegations, the nature of recovery, and the statutory bar under Section 37. It found that the medical condition did not disable the petitioner or require specialised treatment incompatible with custody. It emphasised that the trial was moving at a proper pace and that no undue delay was expected. It held that prolonged custody or medical grounds did not arise in this case.

Decision: The petition was dismissed. The Court held that the petitioner did not satisfy the twin conditions of Section 37 NDPS Act and was not entitled to regular bail. All pending applications were disposed of.