Case Name: Sachin Nagar v. State of Haryana
Date of Judgment: October 06, 2025
Citation: CRM-M-56695-2025
Bench: Hon’ble Mr. Justice Sumeet Goel
Held: The Punjab & Haryana High Court dismissed the anticipatory bail plea filed by the petitioner under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), in connection with an FIR registered for offences under Sections 309(4) of the Bharatiya Nyaya Sanhita, 2023 (BNS) and Sections 25, 54, and 59 of the Arms Act, 1959. The Court held that the allegations were serious, involving armed robbery and recovery of looted valuables, and that custodial interrogation was indispensable to ensure effective investigation. Referring to Kishor Vishwasrao Patil v. Deepak Yashwant Patil (SLP (Crl.) No. 1125 of 2022), State v. Anil Sharma (1997) 7 SCC 187, and Sushila Agrawal v. State (NCT of Delhi) (2020) 5 SCC 1, the Court reiterated that anticipatory bail is an extraordinary remedy to be exercised sparingly and not where custodial interrogation is required.
Summary: The FIR, registered at Police Station Ferozepur Jhirka, District Nuh, alleged that the complainant Sanju and his companion Lalit Kumar were stopped at gunpoint by three individuals in a black Scorpio without a registration plate while travelling on the Delhi–Mumbai Expressway. The assailants robbed them of gold ornaments — including a 3-tola chain, a 5-tola bracelet, a gold ring — and ₹50,000 in cash before fleeing. The petitioner, though not named in the FIR, was later implicated based on the disclosure of a co-accused, Rohit alias Jiva, who identified him as the owner of the getaway vehicle and as having sold the stolen gold bracelet and handed the proceeds to him.
The petitioner’s counsel argued that he was falsely implicated based on disclosure statements alone, that no recovery was pending, and that he was willing to join investigation. The State opposed the plea, emphasizing that the vehicle used belonged to the petitioner, the sale proceeds were traced to him, and custodial interrogation was necessary to identify other accomplices and recover remaining property.
Justice Sumeet Goel examined Supreme Court precedents emphasizing the balance between personal liberty and societal interest. The Court noted that the petitioner had criminal antecedents, the investigation was ongoing, and custodial interrogation was vital to uncover the broader conspiracy and other potential participants.
Decision: The High Court held that serious allegations supported by preliminary investigation justified denial of anticipatory bail. The Court found that releasing the petitioner at this stage could prejudice investigation and lead to tampering with evidence or influencing witnesses. It concluded that the petitioner did not deserve pre-arrest protection and dismissed the petition as devoid of merit, clarifying that no opinion was expressed on the merits of the case or investigation.