Punjab & Haryana High Court Denies Anticipatory Bail in Armed Bank Robbery Case; Finds Custodial Interrogation Essential for Uncovering Criminal Conspiracy

Case Name: Sajan Singh @ Akash Jha vs. State of Punjab
Date of Judgment: 20 November 2025
Citation: CRM-M-65505-2025
Bench: Hon’ble Mr. Justice Sumeet Goel

Held: The Punjab and Haryana High Court dismissed the petition for anticipatory bail filed under Section 482 BNSS, holding that the allegations of an armed bank robbery attempt were extremely serious and that custodial interrogation of the petitioner was indispensable for a fair and comprehensive investigation. The Court observed that the petitioner’s alleged involvement as part of an armed gang, the nature of the weapons used, the injuries caused to the complainant, and the continuing need to trace weapons and co-accused justified denial of pre-arrest protection. The Court relied on multiple Supreme Court precedents emphasizing that anticipatory bail is an extraordinary remedy, especially in cases involving serious offences, and should not be granted when custodial interrogation is necessary.

Summary: The FIR was registered after an attempted armed robbery at Muthoot Fincorp in Ludhiana, where four assailants entered the branch pretending to mortgage a gold chain, suddenly took out weapons, demanded locker keys, and assaulted the branch manager. One of the attackers fired a shot, injuring the complainant. The security guard returned fire, injuring one assailant who later died. The remaining attackers fled. Subsequent investigation identified the deceased attacker and later nominated the petitioner as an accused. The police learnt that the petitioner was already in custody in West Bengal in another violent robbery case, but production warrants could not be executed as the concerned court refused transfer permission.

The petitioner argued that he was falsely implicated, no material linked him to the attack, and since he was already lodged in Asansol Correctional Home, there was no risk of absconding. He submitted that custodial interrogation was unnecessary, the FIR lacked clarity, and he was willing to cooperate with the investigation.

The State opposed the plea, submitting that the petitioner was part of a gang involved in multiple armed robberies, and that custodial interrogation was crucial to ascertain the conspiracy, uncover the chain of events, recover weapons, and identify other participants. The State stressed that releasing the petitioner at this stage would hamper investigation, especially given the violent nature of the crime.

The Court cited authoritative Supreme Court decisions, including Kishor Vishwasrao Patil, Adri Dharan Das, Jai Prakash Singh, and the Constitution Bench judgment in Sushila Aggarwal, reiterating that anticipatory bail is not meant to obstruct fair investigation, that custodial interrogation may be vital in complex, violent crimes, and that such relief must be granted only in exceptional circumstances. The Court found no such circumstances in this case.

Decision: The petition for anticipatory bail was dismissed. The Court held that given the gravity of the armed robbery attempt, the petitioner’s alleged gang involvement, and the pending need to recover weapons and trace co-accused, custodial interrogation was indispensable. The Court concluded that granting anticipatory bail would impede effective investigation. It clarified that nothing in the order would affect the merits of the prosecution case.