Case Name: Sanjay Kumar @ Sunjay Kumar v. State of U.T. Chandigarh
Date of Judgment: 20 February 2026
Citation: CRM-M-10195-2026
Bench: Hon’ble Mr. Justice Namit Kumar
Held: The Punjab and Haryana High Court held that anticipatory bail is an extraordinary relief to be granted sparingly. Where prima facie allegations disclose inducement on false promise of securing a Government job, extraction of ₹4 lakh, and involvement in multiple similar FIRs coupled with concealment of antecedents, custodial interrogation is justified and the concession of anticipatory bail cannot be granted.
Summary: The petitioner sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 in FIR No. 08 dated 19.01.2026 registered under Section 318(4) of the Bharatiya Nyaya Sanhita, 2023 at Police Station Sector 11, Chandigarh .
As per the prosecution case, the petitioner allegedly met the complainant Harwinder at PGIMER, Chandigarh, allured him with the promise of arranging a Government job, and extracted ₹4 lakh from him. The amount was allegedly taken dishonestly with no intention to fulfill the promise .
The defence contended that the petitioner was innocent and falsely implicated. It was argued that the money was a friendly loan which could not be repaid, leading to the lodging of the FIR. The petitioner expressed willingness to join investigation.
Opposing the plea, the State submitted that the petitioner was a habitual offender and involved in four other cases of similar nature. The details of the FIRs, as reflected in the order (page 2), included cases under Sections 420 and 406 IPC at Hajipur, Hoshiarpur and Phase-11, Mohali . Despite this, in paragraph 19 of the petition, the petitioner had stated that he was not involved in any other case, amounting to active concealment.
The Court observed that a person who approaches the Court without clean hands is not entitled to equitable relief. Reliance was placed on Kusha Duruka v. State of Odisha and State of Madhya Pradesh v. Pradeep Sharma, reiterating that anticipatory bail is to be granted only in exceptional circumstances .
Further relying on Bal Krishan Fauzdar v. State of Haryana, the Court emphasized that custodial interrogation is more elicitation-oriented and necessary for fair and effective investigation. It was noted that the complainant was not the only alleged victim and that the petitioner was involved in multiple similar cases.
The Court held that granting anticipatory bail at this stage could impede investigation and embolden the petitioner to influence or intimidate witnesses. Given the specific allegations, antecedents, and concealment, no case for anticipatory bail was made out.
Decision: The petition for anticipatory bail was dismissed .