Punjab & Haryana High Court Refuses Anticipatory Bail in Traffic Challan Tampering Case; Holds Custodial Interrogation Necessary in Corruption and Forgery Offences
Case Name: Ram Kishan v. State of Haryana
Date of Judgment: 14 January 2026
Citation: CRM-M-1385-2026
Bench: Hon’ble Mr. Justice Sumeet Goel
Held: The Punjab and Haryana High Court dismissed the petition seeking anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, holding that anticipatory bail in cases involving tampering of judicial records, corruption, and manipulation of traffic challans is an extraordinary relief to be granted only in exceptional circumstances. The Court held that where allegations disclose a prima facie case of collusion, illegal monetary transactions, and interference with the administration of justice, custodial interrogation is necessary for a fair and effective investigation.
Summary: The petitioner sought pre-arrest bail for offences under various provisions of the Bharatiya Nyaya Sanhita, 2023 and Section 7 of the Prevention of Corruption Act, 1988. The FIR stemmed from a discreet enquiry ordered by the District and Sessions Judge, Faridabad, into irregularities in the Postal Traffic Challan Branch of the Sessions Division.
The enquiry revealed unauthorized access to the CIS system of Magistrate Courts, manipulation of traffic challans by downgrading serious offences into minor ones, and disposal of challans upon payment of illegal gratification. During investigation, it was found that multiple challans relating to heavy motor vehicles were tampered with and disposed of through court processes. Bank transactions and UPI transfers disclosed a chain of illegal payments involving Home Guards and court staff. The petitioner, a clerk/munshi in the Court Complex, Faridabad, was alleged to have acted in collusion with co-accused persons and to have transferred amounts to the bank account of a co-accused, leading to his nomination in the FIR.
The petitioner contended that he had no control over editing of traffic challans, that custodial interrogation would be punitive, and that he was willing to cooperate with the investigation. The State opposed the plea, submitting that the allegations were grave, involved corruption within the judicial system, and that custodial interrogation was essential to unravel the conspiracy and trace the flow of illegal funds.
The High Court, after examining the material on record, held that the investigation was at a preliminary stage and that the petitioner had failed to demonstrate false implication. Relying upon Supreme Court precedents including Kishor Vishwasrao Patil v. Deepak Yashwant Patil, Siddharam Satlingappa Mhetre v. State of Maharashtra, and State v. Anil Sharma, the Court reiterated that anticipatory bail should not be granted where it may hamper investigation, particularly in cases involving economic offences, corruption, and tampering with public records. The Court emphasised that custodial interrogation is often indispensable in such cases to unearth the truth and protect societal interests.
Decision: The petition was dismissed. The High Court held that the petitioner did not deserve the concession of anticipatory bail in view of the gravity of allegations, prima facie material indicating involvement, and the necessity of custodial interrogation for an effective and fair investigation.