Punjab & Haryana HC: Anticipatory Bail Denied in Forged Judicial Summons Case, Court Stresses Gravity of Offence Undermining Justice System
Case Name: Rinku Sharma v. State of Haryana
Date of Judgment: September 29, 2025
Citation: CRM-M-37719-2025
Bench: Hon’ble Mr. Justice Sumeet Goel
Held: The High Court dismissed the petition for anticipatory/pre-arrest bail filed under Section 482 of the BNSS, 2023, noting the serious allegations of preparing and circulating forged judicial summons purportedly issued by the Court of Additional Sessions Judge, Hisar. The Court held that impersonating judicial authority, fabricating summons, and demanding money strike at the sanctity of the justice delivery system and erode public confidence. Even though parties claimed to have reached a settlement, the Court ruled that compromise cannot dilute the seriousness of such an offence. Custodial interrogation was found necessary to trace the origin of the forged documents, examine devices, and uncover possible larger conspiracy.
Summary: The FIR was registered on the complaint of one Sunil, who received via WhatsApp two forged judicial summons allegedly sent by co-accused Deepak Berwal, directing his appearance during summer vacations and falsely asserting registration of an FIR against him, along with a demand to pay ₹10 lakh to one Mishi Sharma as maintenance. Investigation revealed screenshots and disclosure statements linking the petitioner, Rinku Sharma @ Missy Sharma, to the conspiracy, allegedly driven by a matrimonial dispute with Sunil’s son. The petitioner contended she was not named in the FIR, that her implication was based only on co-accused disclosure without corroboration, and that she herself was a victim of blackmail and harassment. She argued nothing remained to be recovered from her and compromise had been reached. The State opposed bail, citing recovery of screenshots, WhatsApp chats, and disclosure statement directly implicating her. The Court relied on Sumitha Pradeep v. Arun Kumar C.K. (2022) and State v. Anil Sharma (1997), reiterating that anticipatory bail cannot be granted merely because custodial interrogation may not seem necessary, as prima facie evidence and gravity of offence are paramount.
Decision: The High Court dismissed the anticipatory bail petition, holding that in view of the gravity of allegations, prima facie material on record, and the necessity of custodial interrogation for a fair and effective investigation, the petitioner was not entitled to protection against arrest.