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2018 DAILYLAW 5583 (PNJ)

SANJEEV KAUL DUGGAL AND ORS v. STATE OF PUNJAB

CRM-M/23866/2018 · 2026-08-27

Virinder Aggarwal

body2018

Judgment text

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CRM-M-23781-2018 & Connected cases -: 1 :- IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH (129 Four Cases) Date of Decision: 27.08.2026 1. CRM-M-23781-2018 Sanjeev Kaul Duggal and Others .... Petitioners Versus State of Punjab .... Respondent 2. CRM-M-23798-2018 Sanjeev Kaul Duggal and Others .... Petitioners Versus State of Punjab .... Respondent 3. CRM-M-23834-2018 Sanjeev Kaul Duggal and Others .... Petitioners Versus State of Punjab .... Respondent 4. CRM-M-23866-2018 Sanjeev Kaul Duggal and others .... Petitioners Versus State of Punjab .... Respondent CORAM: HON'BLE MR. JUSTICE VIRINDER AGGARWAL Present : Mr. Akshay Bhan, Senior Advocate with Mr. Lakshey Bector, Advocate and Mr. Ajay Chawla, Advocate for the petitioners. Mr. Baljnder Singh Sra, Additional AG, Punjab. **** VIRINDER AGGARWAL , J. (Oral) GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 2 :- 1. This order shall dispose of the present four petitions, as they arise from the same set of proceedings pending before the learned Chief Judicial Magistrate, Patiala, involve common petitioners and give rise to substantially overlapping questions of fact and law. In view of the commonality of the factual and legal matrix, these petitions are being adjudicated upon by this common judgment. 2. For facility of reference, CRM-M-23866-2018 and CRM-M- 23834-2018 assail the criminal proceedings and the summoning order dated 07.11.2012 passed by the learned Chief Judicial Magistrate, Patiala, whereas CRM-M-23798-2018 and CRM-M-23781-2018 call in question the subsequent order dated 03.01.2018, whereby the petitioners were declared proclaimed offenders. 3. The controversy, in substance, lies within a narrow compass. The petitioners assert that they were never named or arrayed as accused in the complaints; no judicial process was ever issued against them in their individual names; no valid summons were served upon them; and, consequently, there could arise no legally sustainable basis for treating them as persons deliberately evading the process of law and, thereafter, invoking the extraordinary coercive procedure contemplated under Section 82 of the Code of Criminal Procedure, 1973. 4. The underlying proceedings emanate from Complaint No.41 dated 07.11.2012 and Complaint No.42 dated 20.11.2012, instituted under Sections 59 and 425 of the Food Safety and Standards Act, 2006, read with the Rules/Regulations framed thereunder. Complaint No.41 arose out of an inspection conducted at an Easy Day Market outlet situated at Omaxe Mall, GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 3 :- Patiala, in connection with a sample of ginger, whereas Complaint No.42 emanated from an inspection of another Easy Day Market outlet at Bhadson Road, Patiala, concerning samples of natural jaggery. The complaints essentially referred to the concerned store managers and, in general terms, to the company/nominee/partner/MD/proprietor/director, without individually identifying the present petitioners or attributing any specific role to them. The consistent case of the petitioners is that they were neither individually named in the complaints nor subjected to any specific process of law in their respective names. The paper books, as placed on record, also disclose their specific assertion that no summons were ever issued or served upon them individually pursuant to the institution of the complaints. 5. The learned Chief Judicial Magistrate, Patiala, passed the summoning order dated 07.11.2012. The principal grievance of the petitioners is that the said order neither adverts to any specific role allegedly attributable to them nor individually identifies or summons them by name. Aggrieved thereby, the petitioners invoked the inherent jurisdiction of this Court under Section 482 Cr.P.C. However, notwithstanding the pendency of the proceedings before this Court, the proceedings before the learned Trial Court continued. The zimni orders forming part of the record assume considerable significance in this regard. They indicate that the process was initially directed to the company/address and that, subsequently, proceedings came to be pursued against persons described merely as accused Nos.2 and 3, without their names having been specifically incorporated either in the original complaints or in the process in the manner contemplated by law. 6. The record further reveals that, on 29.11.2017, a Food Clerk of the department moved an application before the learned Trial Court seeking to GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 4 :- furnish the names and addresses of the persons against whom the proceedings were sought to be continued. The specific case of the petitioners is that their names were procured from the internet on the premise that they were directors of Bharti Retail Limited. The aforesaid development assumes considerable significance, inasmuch as the petitioners were sought to be identified and brought into the proceedings almost five years after the original summoning order dated 07.11.2012, without any demonstrable antecedent of valid service of judicial process upon them individually. The subsequent zimni orders further indicate that the learned Trial Court proceeded on the premise that the summons issued to the concerned accused had not been received back and thereafter proceeded to issue bailable as well as non-bailable warrants. However, the record does not disclose any legally sustainable or demonstrable service of such process upon the petitioners individually prior to the initiation of coercive measures against them. 7. Thereafter, the learned Trial Court proceeded to invoke Section 82 Cr.P.C. and directed issuance of proclamation against accused Nos.2 and 3. The proclamation was stated to have been effected at the premises described as the office of Bharti Retail Limited, situated at Centrum Plaza, Tower-C, 2nd Floor, Golf Course Road, Sector 53, Gurgaon. Significantly, however, the material forming part of the record indicates that Bharti Retail Limited had ceased to occupy the said premises as early as April, 2014. The petitioners have placed on record the settlement deed and the note regarding handing over of physical possession dated 04.04.2014, to substantiate their contention that the premises were no longer in the occupation of Bharti Retail Limited when the proclamation proceedings were undertaken. They have also relied upon subsequent corporate documents evidencing the change of name of Bharti GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 5 :- Retail Limited to Future Retail Limited in 2016. Eventually, on 03.01.2018, the learned Trial Court recorded that the statutory period of one month from the issuance of proclamation had elapsed and, noticing the non-appearance of accused Nos.2 and 3, proceeded to declare them proclaimed offenders. It is this order dated 03.01.2018 which is specifically assailed in CRM-M-23781-2018 and CRM-M-23798-2018, whereas the other two petitions assail the foundational criminal proceedings and the summoning order dated 07.11.2012. 8. Learned Senior counsel for the petitioners submits that the entire subsequent course of proceedings stands vitiated at its very foundation. It is contended that a person who was never individually summoned by name and at his proper address cannot, in the absence of valid service of judicial process, be presumed to have deliberately evaded the process of the Court. Learned Senior counsel submits that the names of the petitioners did not figure in the original complaints; they were never specifically arrayed as accused therein; and their subsequent identification from information downloaded from the internet could not, by itself, furnish a legally tenable basis to presume that they had been duly arraigned or summoned as accused. It is further contended that the proclamation proceedings were undertaken against persons who had neither been duly arraigned as accused nor personally served with judicial process, and in respect of whom there was no material demonstrating that they had absconded or were deliberately concealing themselves to evade execution of warrants. Learned Senior counsel also draws attention to the fact that the proclamation was allegedly effected at premises which had ceased to be occupied by Bharti Retail Limited in April, 2014. On these premises, it is submitted that the entire exercise culminating in the declaration of the petitioners as proclaimed GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 6 :- offenders is legally unsustainable and amounts to an abuse of the process of the Court. Accordingly, allowing of the petitions has been prayed for. 9. Per contra, learned State counsel has vehemently opposed the petitions and placed reliance upon the proceedings recorded by the learned Trial Court, as also the reports pertaining to service of summons, issuance of warrants and execution of proclamation. It is submitted that the petitioners were proceeded against pursuant to the successive orders passed by the learned Trial Court and that the reports forming part of the judicial record reflect the various steps undertaken to secure their presence. Learned State counsel, therefore, submits that no jurisdictional or procedural infirmity warranting interference in exercise of the inherent jurisdiction of this Court has been demonstrated. Dismissal of the petitions has, accordingly, been prayed for. 10. I have heard learned counsel for the parties at considerable length and, with their able assistance, have carefully perused the paper books as well as the material placed on record. 11. The petitioners were neither named nor arrayed as accused in the complaints; their names surfaced only on 29.11.2017 through the Food Clerk’s application, allegedly based on information downloaded from the internet showing them as Directors of Bharti Retail Limited. No valid summons or warrants were ever issued and served upon them individually. Their subsequent identification could neither retrospectively validate judicial process nor justify invocation of Section 82 Cr.P.C., which presupposes valid process against the particular individual and deliberate abscondence or concealment. The proclamation, moreover, was effected at the erstwhile office of Bharti Retail Limited at Centrum Plaza, Gurgaon, despite the settlement deed and possession GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 7 :- note dated 04.04.2014 indicating that the premises had already been vacated. There is no cogent material showing knowledge and deliberate evasion on the part of the petitioners, who consistently asserted that they learnt of the proceedings only in 2018. Equally, the summoning order dated 07.11.2012 records no application of judicial mind to their individual role or culpability, nor any material establishing that they were in charge of and responsible for the company’s business; mere designation or alleged directorship cannot ipso facto sustain their prosecution. 12. The contours and parameters governing exercise of the inherent jurisdiction of this Court to quash criminal proceedings under Section 482 Cr.P.C. (now Section 528 of the BNSS) are well settled. The Hon’ble Supreme Court, in the landmark judgment of State of Haryana & Ors. vs. Ch. Bhajan Lal & Ors., 1991 (1) RCR(Criminal) 383, has illustratively delineated the categories of cases in which such extraordinary jurisdiction may legitimately be exercised, either to prevent abuse of the process of any Court or otherwise to secure the ends of justice. The said principles, while not constituting an exhaustive or inflexible formula, furnish the settled parameters within which the extraordinary jurisdiction of the High Court is required to be exercised, which are as under:- “107. In the backdrop of the interpretation of the various relevant provisions of the Code under Chapter XIV and of the principles of law enunciated by this Court in a series of decisions relating to the exercise of the extraordinary power under Article 226 or the inherent powers under section 482 of the Code which we have extracted and reproduced above, we give the following categories of cases by way of illustration wherein such power could be exercised either to prevent abuse of the process of any Court or otherwise to secure the ends of justice, though it may not be possible to lay down any precise, clearly defined and sufficiently channelised and GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 8 :- inflexible guidelines or rigid formulae and to give an exhaustive list of myriad kinds of cases wherein such power should be exercised. 1. Where the allegations made in the First Information Report or the complaint, even if they are taken at their face value and accepted in their entirety do not prima facie constitute any offence or make out a case against the accused. 2. Where the allegations in the First Information Report and other materials, if any, accompanying the F.I.R. do not disclose a cognizable offence, justifying an investigation by police officers under Section 156 (1) of the Code except under an order of a Magistrate within the purview of Section 155(2) of the Code. 3. Where the uncontroverted allegations made in the FIR or complaint and the evidence collected in support of the same do not disclose the commission of any offence and make out a case against the accused. 4. Where, the allegations in the F.I.R. do not constitute a cognizable offence but constitute only a non-cognizable offence, no investigation is permitted by a police officer without an order of a Magistrate as contemplated under Section 155(2) of the Code. 5. Where the allegations made in the F.I.R. or complaint are so absurd and inherently improbable on the basis of which no prudent person can ever reach a just conclusion that there is sufficient ground for proceeding against the accused. 6. Where there is an express legal bar engrafted in any of the provisions of the Code or the concerned Act (under which a criminal proceeding is instituted) to the institution and continuance of the proceedings and/or where there is a specific provision in the Code or the concerned Act, providing efficacious redress for the grievance of the aggrieved party. 7. Where a criminal proceeding is manifestly attended with mala fide and/or where the proceeding is maliciously instituted with an ulterior motive for wreaking vengeance on the accused and with a view to spite him due to private and personal grudge. 108. We also give a note of caution to the effect that the power of quashing a criminal proceeding should be exercised very sparingly and with circumspection and that too in the rarest of rare cases; that the Court will not be justified in embarking upon an enquiry as to the reliability or genuineness or otherwise of the allegations GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 9 :- made in the F.I.R. or the complaint and that the extraordinary or inherent powers do not confer an arbitrary jurisdiction on the Court to act according to its whim or caprice.” 13. In M/s. Neeharika Infrastructure Pvt. Ltd. vs. State of Maharashtra, (2021) 19 SCC 401, a three-Judge Bench of the Hon’ble Supreme Court reiterated and elaborately examined the settled parameters governing exercise of the inherent jurisdiction under Section 482 Cr.P.C. It was reiterated that the power to quash criminal proceedings is extraordinary in nature and is required to be exercised sparingly, with circumspection and in the rarest of rare cases, such expression being understood in the context of exercise of inherent jurisdiction and not equated with the standard applicable to cases involving capital punishment. The Hon’ble Supreme Court further cautioned that, while examining an FIR or complaint, the High Court ought not to embark upon an enquiry into the reliability, genuineness or otherwise of the allegations or undertake an appreciation of the evidence. At the same time, where the case falls within the recognised parameters for exercise of inherent jurisdiction, and having regard to the principles enunciated in R.P. Kapur vs. State of Punjab, AIR 1960 SC 866, and State of Haryana and others vs. Bhajan Lal, supra, the High Court would be fully competent to interdict and quash the criminal proceedings in order to prevent abuse of the process of law or to secure the ends of justice. 14. Tested on the aforesaid touchstone, the present case falls squarely within the permissible contours of exercise of inherent jurisdiction. The allegations contained in the complaints, read in conjunction with the material placed on record, fail to disclose the requisite factual foundation for fastening criminal liability upon the present petitioners in their individual capacity. Significantly, the petitioners are neither named nor individually arrayed as GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 10 :- accused in the complaints, nor do the complaints contain the necessary averments attributing to them any specific role or connecting them with the statutory liability contemplated under Section 66 of the Food Safety and Standards Act. Their subsequent identification merely as persons associated with or allegedly holding the position of directors in the company cannot, by itself, cure the foundational defect, supply the conspicuously absent statutory ingredients or retrospectively validate the issuance of criminal process against them. 15. The fact that the petitioners were never duly arrayed as accused is borne out, in the first instance, from the very memo of parties accompanying the complaints, which is reproduced hereunder for facility of reference: - “State Vs. 1. Pradyumn Gurtu, S/o Pradeeep Gurtu Store Manager of Bharti Retail Limited, Easy Day Market, Omaxe Mall, Opposite Kali Mata Mandir, Patiala R/o 52A, Model Town, Patiala. 2. Nominee Partner/M.D./Prop/Director of Bharti Retail Limited, Centrum Plaza, Tower C, 2nd Floor, Golf Course Road, Sector 53, Gurgaon 122002.” 15.1. Likewise, the summoning order dated 07.11.2012 was passed without specifically identifying or naming the accused against whom the process was purportedly being issued. The operative portion of the said order, which assumes significance for determining the validity of the subsequent proceedings, reads as under:- xxxx “Heard File perused. The sample in this case was taken and found to be unsafe for human consumption upon analysis. Thus from the facts GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 11 :- mentioned in the complaint and other document on the file there are sufficient grounds to proceed against the accused under the Act. Accordingly, accused be summoned for 23.01.13.” 16. At the stage of taking cognizance and issuing process, the learned Chief Judicial Magistrate was required to examine the complaints and the material placed on record with due application of judicial mind, particularly with a view to ascertain the identity of the persons against whom process was sought to be issued and the factual basis for fastening criminal liability upon each such individual. However, the record reveals that, at the time of passing the summoning order, the learned Chief Judicial Magistrate failed to take note of the fundamental fact that accused No.2 in Complaint No.41 dated 07.11.2012 and accused Nos.2 and 3 in Complaint No.42 dated 20.11.2012 had not been specifically named or individually identified in the respective memos of parties. There was, in fact, no identifiable individual answering to the description of accused No.2 in Complaint No.41 dated 07.11.2012 or accused Nos.2 and 3 in Complaint No.42 dated 20.11.2012. Thus, the summoning order, insofar as it purported to initiate criminal process against such unnamed and unidentified persons, suffers from a manifest infirmity and reflects a failure to apply the requisite judicial mind to the very identity and legal status of the persons sought to be proceeded against. 16.1. It is a settled principle that issuance of criminal process is not a mechanical or routine exercise, but a serious judicial act having far-reaching consequences for the person summoned. Although the Magistrate is not required, at that stage, to record an elaborate or detailed judgment, the order issuing process must nevertheless evince due and conscious application of judicial mind to the allegations, the material placed on record and the necessity GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 12 :- of proceeding against the particular person sought to be summoned. In Pepsi Foods Ltd. and another vs. Special Judicial Magistrate and others, 1998 (5) SCC 749, the Hon’ble Supreme Court categorically held that summoning of an accused in a criminal case is a serious matter and that criminal law cannot be set into motion as a matter of course. The Magistrate is required to examine the allegations and the material brought on record and satisfy himself that sufficient grounds exist for proceeding against the person concerned. The said principle was reiterated in Mehmood Ul Rehman vs. Khazir Mohammad Tunda and others, 2015 (12) SCC 420, and more recently in M/s J.M. Laboratories and others vs. State of Andhra Pradesh and another, 2025 INSC 127, wherein the Hon’ble Supreme Court reiterated the necessity of demonstrable application of mind while issuing process and deprecated orders whereby process is issued without due consideration of the material and the basis for proceeding against the accused. 17. The present case presents a more fundamental infirmity. The petitioners were neither named nor individually arrayed as accused in the complaints, nor does the summoning order dated 07.11.2012 contain any specific reference to their names or record any conscious determination that they were being summoned as accused in their individual capacities. Rather, the persons who were actually arrayed as accused in the complaints were summoned. The petitioners came into the picture only subsequently, when summons and warrants issued against the purportedly unnamed accused were returned unserved or unexecuted. It was thereafter that the learned Chief Judicial Magistrate proceeded to initiate coercive proceedings against the petitioners and ultimately directed issuance of proclamation against them. Such a course of action, in the absence of any antecedent judicial order specifically GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 13 :- arraigning and summoning the petitioners as accused and without demonstrating valid service of process upon them individually, could not furnish a lawful foundation for invoking the drastic provisions of Section 82 Cr.P.C. The relevant orders passed by the learned Trial Court, which demonstrate the manner in which the proceedings came to be initiated against the petitioners, are reproduced hereunder for facility of reference:- 17.1. In these orders also names of petitioners were no-where figured. It is only accused No.2 and accused Nos.2 and 3 of respective complaints who were declared proclaimed offenders and petitioners have not been arrayed as accused in complaint cases. Orders are totally result of non-application of mind on the part of the Court below and are cryptic. 17.2. The learned Chief Judicial Magistrate also failed to appreciate that the petitioners had neither been arrayed as accused in the complaints nor GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 14 :- summoned to face trial in their individual capacities. Even the order directing service through proclamation under Section 82 Cr.P.C. was not preceded by any specific judicial process issued against the petitioners by name. In these circumstances, the invocation of Section 82 Cr.P.C. against the petitioners was not merely irregular but fundamentally misconceived, since the said provision presupposes the existence of a valid warrant against the particular person and a judicially sustainable satisfaction that such person has absconded or is concealing himself so as to evade execution thereof. 17.3. The entire sequence of proceedings, therefore, reflects a manifest failure to adhere to the statutory safeguards and betrays a conspicuous absence of the requisite application of judicial mind at successive stages. The petitioners could not, in the absence of having been duly arraigned, summoned and subjected to valid judicial process, have been proceeded against under Section 82 Cr.P.C. or ultimately declared proclaimed offenders. The proclamation proceedings, consequently, stand vitiated in law and cannot be permitted to operate against the petitioners. 18. Proclamation in the names of the petitioners was, therefore, issued in patent disregard of the statutory scheme and the following foundational infirmities, inter alia, render the entire exercise unsustainable in law:- i. Petitioners were never arrayed as accused in the complaints. ii. Petitioners were never ordered to be summoned as an accused to face trial. iii. Petitioners were never served with any summons nor any non- bailable warrants were issued against the petitioners warranting a finding of the Court that petitioners are concealing their presence or are avoiding the service of warrants and summons. GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 15 :- 18.1. Moreover, the statutory scheme embodied in Section 82(4) Cr.P.C. assumes significance. Even otherwise, having regard to the nature of the offences alleged in the present complaints, the petitioners could not have been declared proclaimed offenders and, at the highest, could have been declared only ‘proclaimed persons’, if the statutory conditions for such a declaration were otherwise satisfied. This aspect assumes added significance in the present case, where the petitioners were neither named nor arrayed as accused in the complaints, no summoning order specifically identified or summoned them by name, and no valid judicial process had been shown to have been issued against them individually. The entire exercise of subjecting the petitioners to proclamation proceedings and thereafter declaring them proclaimed offenders was, therefore, undertaken in patent disregard of the statutory scheme of Section 82 Cr.P.C. and cannot be sustained in law. 19. The continuation of the complaints and the consequential proceedings against the petitioners would, therefore, amount to permitting criminal prosecution to subsist in the absence of the foundational factual and legal substratum necessary to sustain their prosecution. Such continuation, in the peculiar facts and circumstances of the present case, would constitute a manifest abuse of the process of the Court and falls squarely within the well- recognised parameters warranting exercise of the inherent jurisdiction of this Court to secure the ends of justice. 20. In view of the foregoing discussion and the cumulative effect of the aforesaid infirmities, the petitions deserve to be allowed. Consequently, the criminal proceedings, including the complaints, the summoning order and the GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 16 :- subsequent orders whereby the petitioners were declared proclaimed offenders, insofar as they relate to the present petitioners, are liable to be quashed. 21. Accordingly, this Court finds that the proceedings against the present petitioners cannot be legally sustained. The orders dated 03.01.2018 declaring the petitioners proclaimed offenders are unsustainable for want of compliance with the foundational requirements of Section 82 Cr.P.C. The summoning order dated 07.11.2012, insofar as it purports to operate against the present petitioners, does not disclose the requisite application of judicial mind qua their individual identity, role or alleged culpability. Furthermore, the complaints themselves do not furnish the necessary factual and statutory foundation for fastening criminal liability upon the petitioners in their individual capacities. 22. Consequently, the present petitions are allowed. The orders dated 03.01.2018 passed by the learned Chief Judicial Magistrate, Patiala, whereby the petitioners were declared proclaimed offenders, are hereby quashed and set aside. The summoning order dated 07.11.2012, insofar as it concerns the present petitioners, is also quashed and set aside. 23. As a necessary corollary, the criminal proceedings arising out of Complaint No.41 dated 07.11.2012 and Complaint No.42 dated 20.11.2012, including the said complaints themselves, are hereby quashed qua the present petitioners. All consequential proceedings emanating therefrom against the present petitioners shall also stand quashed. 24. It is, however, clarified that the benefit of this judgment shall operate strictly qua the present petitioners. The criminal proceedings, if any, against the remaining accused shall remain wholly unaffected by the present GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document CRM-M-23781-2018 & Connected cases -: 17 :- judgment. The learned Trial Court shall take due note of this order and ensure that no coercive process survives or is acted upon against the present petitioners on the strength of the proceedings or orders quashed herein. 25. In view of the final disposal of the principal proceedings, all pending miscellaneous application(s), if any, arising therefrom or ancillary thereto, shall stand disposed of accordingly. No separate or further orders are warranted in respect thereof. 26. Photocopy of this order be placed on each of the connected files for record, ready reference and compliance, if any. (VIRINDER AGGARWAL) JUDGE 27.08.2026 S. Pathania/Gaurav Sorot Whether speaking/reasoned Yes/No Whether Reportable Yes/No GAURAV SOROT 2026.09.03 16:35 I attest to the accuracy and integrity of this document