Punjab & Haryana High Court Denies Anticipatory Bail to Woman Accused in ₹20 Lakh IELTS Immigration Fraud Case
Case Name: Shikha Sharma v. State of Punjab
Date of Judgment: October 14, 2025
Citation: CRM-M-57539-2025
Bench: Hon’ble Mr. Justice Sumeet Goel
Held: The Punjab & Haryana High Court dismissed a plea for anticipatory bail filed by a woman accused of defrauding ₹20 lakh from a complainant under the guise of providing IELTS admission and immigration services. Justice Sumeet Goel held that the allegations revealed a serious financial fraud involving deliberate misrepresentation and breach of trust, warranting custodial interrogation. The Court ruled that the gravity and magnitude of the offence, coupled with the petitioner’s active role, justified denial of pre-arrest bail.
Summary: The petitioner, Shikha Sharma, sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in FIR No. 229 dated July 3, 2023, registered at Police Station City Faridkot under Sections 420, 406, and 120-B IPC. The FIR was filed by Bhupinder Singh of Moga, who alleged that his son was cheated of ₹20 lakh by Shikha Sharma, her husband Deepak Sharma, and another accused, Arshdeep Singh, on the pretext of securing IELTS admission and overseas study arrangements. The complainant stated that ₹15 lakh was paid in August 2022 and another ₹5 lakh in May 2023, after which the accused switched off their phones and shut their office.
The petitioner contended that she was falsely implicated, had no connection with her estranged husband’s firm “SBE Visa Immigration Consultant,” and was in Dubai for her daughter’s medical treatment at the time of the FIR. The State opposed bail, arguing that she had directly demanded ₹5 lakh and played an active role in the fraudulent transaction. The Court observed that multiple similar complaints had been filed against the accused, showing a pattern of deceit.
Justice Goel emphasized that the offence involved organized immigration fraud, eroding public trust and necessitating firm judicial response. He cited State v. Anil Sharma (1997) 7 SCC 187 to underscore that custodial interrogation was essential to uncover the full scope of conspiracy and recover the defrauded money. The Court also rejected her plea for parity with co-accused Arshdeep Singh, noting that her role was distinct and graver.
Decision: The High Court dismissed the petition, holding that given the seriousness of the allegations, the petitioner’s prima facie involvement, and the need for custodial interrogation, she did not deserve the concession of anticipatory bail. All pending applications were disposed of.