Punjab & Haryana High Court Declines Anticipatory Bail to NDPS Accused; Holds Custodial Interrogation Necessary to Unravel Narcotics Supply Chain

Case Name: Ranjit Ray v. Directorate of Revenue Intelligence, Ludhiana
Date of Judgment: 11 December 2025
Citation: CRM-M-68682-2025
Bench: Hon’ble Mr. Justice Sumeet Goel

Held: The Punjab and Haryana High Court refused to grant anticipatory bail to the petitioner accused of involvement in trafficking of commercial quantity of ganja, holding that the material on record prima facie established his possession of the vehicle used for transportation of contraband and his active role in the supply chain. The Court held that custodial interrogation was essential to uncover the larger conspiracy, identify other accomplices, and ensure effective investigation under the NDPS Act.

Summary: The petition arose from recovery of 31.352 kg of ganja from a car found abandoned in Ludhiana. Investigation by the Directorate of Revenue Intelligence traced the ownership and possession of the vehicle through a chain of transfer documents, affidavits, delivery receipts, and statements recorded under Section 67 of the NDPS Act. The investigation ultimately established that the vehicle had come into possession of the petitioner shortly before the recovery.

The petitioner sought anticipatory bail contending that he was neither the registered owner nor present at the spot, that no recovery had been effected from him, and that he had already sold the vehicle to another person. It was further argued that his custodial interrogation was unnecessary and that he was willing to join investigation.

The DRI opposed the petition, pointing out that documentary evidence and witness statements clearly linked the petitioner to the vehicle used for transporting contraband. It was also highlighted that the petitioner was already facing trial in another NDPS case involving recovery of 428.13 kg of ganja, indicating habitual involvement in narcotics trafficking. The prosecution further submitted that the petitioner had not joined investigation despite repeated summons.

The Court, after examining the material on record, found that the investigation had prima facie established the petitioner’s possession and control over the vehicle used for transporting commercial quantity of ganja. The Court noted the gravity of the offence, the recurring pattern of alleged conduct, and the necessity of custodial interrogation to unearth the broader supply network. Relying on settled principles governing anticipatory bail, including the need to balance individual liberty with societal interest, the Court held that granting pre-arrest bail at this stage would seriously prejudice the investigation.

Decision: The petition for anticipatory bail was dismissed. The Court held that the petitioner did not merit the concession of pre-arrest bail in view of the seriousness of the allegations, the material indicating his involvement, and the necessity of custodial interrogation. The Court clarified that observations made in the order would not be construed as an opinion on the merits of the case.