CRM-M-12198 IN THE HIGH COURT OF PUNJAB AND HARYANA 212 Satish Kumar Garg State of Punjab & Another CORAM: HON’BLE MS. Present: RUPINDERJIT CHAHAL, J (ORAL) 1. Prayer in the instant 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 is for grant of anticipatory dated 23.02 471, 506 of the 12198 of 2026 -1- IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CRM- Date of Decision: Satish Kumar Garg Versus Punjab & Another CORAM: HON’BLE MS. JUSTICE RUPINDERJIT CHAHAL Mr. Vikram Chaudhary, Senior Advocate with Ms. Hargun Sandhu, Advocate and Mr. Rishab Tewari, Advocate for the petitioner. Ms. Amrit Kaur Mahir, AAG, Punjab. Mr. Akshay Bhan, Senior Advocate with Mr. Gurinder Singh, Advocate and Mr. Rahul Dhanda, Advocate for respondent No.2/complainant. ***** RUPINDERJIT CHAHAL, J (ORAL) Prayer in the instant petition filed under Section of the Bharatiya Nagarik Suraksha Sanhita, 2023 is for anticipatory bail to the petitioner in case FIR No. 02.2015 registered under Sections of the Indian Penal Code, 1860 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH -M-12198 of 2026 Date of Decision: 18.05.2026 ....Petitioner ....Respondents JUSTICE RUPINDERJIT CHAHAL Mr. Vikram Chaudhary, Senior Advocate with Ms. Hargun Sandhu, Advocate and Mr. Rishab Tewari, Advocate Ms. Amrit Kaur Mahir, AAG, Punjab. Mr. Akshay Bhan, Senior Advocate with Mr. Gurinder Singh, Advocate and Mr. Rahul Dhanda, Advocate for respondent No.2/complainant. petition filed under Section of the Bharatiya Nagarik Suraksha Sanhita, 2023 is for bail to the petitioner in case FIR No. 09 registered under Sections 420, 467, 468, , 1860 at Police Station City petition filed under Section of the Bharatiya Nagarik Suraksha Sanhita, 2023 is for 09 420, 467, 468, City PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 Malout, Distric 2. The FIR firm, on the statement of complainant late Sh. Shiv Garg was having joint business Vaneet Garg, Satpal Garg, and Satish Garg, and he died in the year 2004, and there were number of joint firms. After the death of Shiv Charan Garg, complainant sons Dinesh Garg and Deepak Garg were inducted as partners in all the join prepared a forged and fabricated retirement deed of complainant, her sons relinquishing their share in the firm, Ram Sarup Garg Cotton Mills, Malout, thus, fraudulently grabbed their share in the 3. Learned Senior Counsel appearing on behalf of the petitioner submitted the process of law, arising out of an admittedly long intra-family and commercial dispute concerning retirement, dissolution and settlement of partnership accounts amongst family members. The allegations pertain to documents executed in the year 2014 pursuant to a family settlement, thereby demolishing the allegation of any contemporaneous fraud or forgery. about 74 years, has been residing in Delhi since 1979 and had 12198 of 2026 -2- Malout, District Sri Muktsar Sahib. The FIR has been registered against partners of the the statement of complainant late Sh. Shiv Charan Garg, on the allegations that Shiv Charan Garg was having joint business with his brothers namely Vaneet Garg, Satpal Garg, and Satish Garg, and he died in the year 2004, and there were number of joint firms. the death of Shiv Charan Garg, complainant Dinesh Garg and Deepak Garg were inducted as partners in all the joint firms. It is also alleged that the accused prepared a forged and fabricated retirement deed of complainant, her sons relinquishing their share in the firm, Sarup Garg Cotton Mills, Malout, thus, fraudulently grabbed their share in the above said firm. Learned Senior Counsel appearing on behalf of the submitted that the present FIR is a gross abuse of the process of law, arising out of an admittedly long family and commercial dispute concerning retirement, solution and settlement of partnership accounts amongst family members. The allegations pertain to documents executed in the year 2014 pursuant to a family settlement, thereby demolishing the allegation of any contemporaneous fraud or forgery. He further submitted about 74 years, has been residing in Delhi since 1979 and had has been registered against partners of the the statement of complainant-Madhu Garg, widow of Charan Garg, on the allegations that Shiv Charan with his brothers namely Vaneet Garg, Satpal Garg, and Satish Garg, and unfortunately he died in the year 2004, and there were number of joint firms. the death of Shiv Charan Garg, complainant and her Dinesh Garg and Deepak Garg were inducted as partners also alleged that the accused prepared a forged and fabricated retirement deed in the name of complainant, her sons relinquishing their share in the firm, Sarup Garg Cotton Mills, Malout, thus, fraudulently ve said firm. Learned Senior Counsel appearing on behalf of the that the present FIR is a gross abuse of the process of law, arising out of an admittedly long-standing family and commercial dispute concerning retirement, solution and settlement of partnership accounts amongst family members. The allegations pertain to documents executed in the year 2014 pursuant to a family settlement, thereby demolishing the allegation of any contemporaneous ubmitted that the petitioner, aged about 74 years, has been residing in Delhi since 1979 and had has been registered against partners of the Madhu Garg, widow of Charan Garg, on the allegations that Shiv Charan with his brothers namely unfortunately he died in the year 2004, and there were number of joint firms. her Dinesh Garg and Deepak Garg were inducted as partners also alleged that the accused in the name of complainant, her sons relinquishing their share in the firm, Sarup Garg Cotton Mills, Malout, thus, fraudulently Learned Senior Counsel appearing on behalf of the that the present FIR is a gross abuse of standing family and commercial dispute concerning retirement, solution and settlement of partnership accounts amongst family members. The allegations pertain to documents executed in the year 2014 pursuant to a family settlement, thereby demolishing the allegation of any contemporaneous he petitioner, aged about 74 years, has been residing in Delhi since 1979 and had PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 no active role in the day administration of the firms situated at Malout, Punjab. The dispute is thus predominantly civil in nature deliberately been given a criminal colour only to exert pressure upon the petitioner and his family members. It is further submitted that the entire case rests upon documentary evidence already in possession of the investigating agency and, therefore, no custodial interrogation is either necessary or justified. He argued that t the doubtful nature of the allegations inasmuch as multiple SITs and investigating agencies have repeatedly submitted cancellation re against the accused persons. Even the forensic material placed on record reveals inconsistencies in the prosecution version and lends support to the defence case regarding authenticity of the disputed documents. throughout cooperated with the investigation allegation that the petitioner attempted to abscond, influence witnesses or tamper with evidence. in the matter of co Hon’ble Supreme Court has directed that no coercive steps be taken during mediation proceedings, thereby recognizing the essentially private and settlement dispute. The p 12198 of 2026 -3- no active role in the day-to-day affairs or financial administration of the firms situated at Malout, Punjab. The dispute is thus predominantly civil in nature deliberately been given a criminal colour only to exert pressure upon the petitioner and his family members. It is further submitted that the entire case rests upon documentary evidence already in possession of the investigating agency and, ore, no custodial interrogation is either necessary or He argued that the investigation history itself reflects the doubtful nature of the allegations inasmuch as multiple SITs and investigating agencies have repeatedly submitted cancellation reports finding no cognizable offence made out against the accused persons. Even the forensic material placed on record reveals inconsistencies in the prosecution version and lends support to the defence case regarding authenticity of the disputed documents. He submitted that t throughout cooperated with the investigation allegation that the petitioner attempted to abscond, influence witnesses or tamper with evidence. He further submitted that in the matter of co-accused pending before the Apex Court, the Hon’ble Supreme Court has directed that no coercive steps be taken during mediation proceedings, thereby recognizing the essentially private and settlement dispute. The petitioner is neither a proclaimed offender nor day affairs or financial administration of the firms situated at Malout, Punjab. The dispute is thus predominantly civil in nature and has deliberately been given a criminal colour only to exert pressure upon the petitioner and his family members. It is further submitted that the entire case rests upon documentary evidence already in possession of the investigating agency and, ore, no custodial interrogation is either necessary or he investigation history itself reflects the doubtful nature of the allegations inasmuch as multiple SITs and investigating agencies have repeatedly submitted ports finding no cognizable offence made out against the accused persons. Even the forensic material placed on record reveals inconsistencies in the prosecution version and lends support to the defence case regarding authenticity of He submitted that the petitioner has throughout cooperated with the investigation and there is no allegation that the petitioner attempted to abscond, influence He further submitted that accused pending before the Apex Court, the Hon’ble Supreme Court has directed that no coercive steps be taken during mediation proceedings, thereby recognizing the essentially private and settlement-oriented nature of the etitioner is neither a proclaimed offender nor day affairs or financial administration of the firms situated at Malout, Punjab. The and has deliberately been given a criminal colour only to exert pressure upon the petitioner and his family members. It is further submitted that the entire case rests upon documentary evidence already in possession of the investigating agency and, ore, no custodial interrogation is either necessary or he investigation history itself reflects the doubtful nature of the allegations inasmuch as multiple SITs and investigating agencies have repeatedly submitted ports finding no cognizable offence made out against the accused persons. Even the forensic material placed on record reveals inconsistencies in the prosecution version and lends support to the defence case regarding authenticity of he petitioner has here is no allegation that the petitioner attempted to abscond, influence He further submitted that accused pending before the Apex Court, the Hon’ble Supreme Court has directed that no coercive steps be taken during mediation proceedings, thereby recognizing the oriented nature of the etitioner is neither a proclaimed offender nor PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 involved in any other criminal case. He petitioner is ready and willing to join investigation as and when called upon to do so by the investigating agency. these submissions present petition be allowed and the petitioner be granted the benefit of anticipatory bail. 4. Learned state counsel has filed status report in the matter and while relying upon the same, she has vehemently opposed the prayer of submitted that the offence committed by the petitioner is serious in nature and he does not deserve any concession from this Court. aside as a mere civil or family disp investigation conducted by multiple Special Investigation Teams has revealed prima facie material demonstrating preparation and use of forged retirement deeds, misuse of signed blank papers and fraudulent exclusion of the complainant an concern, namely M/s Shri Ram Saroop Garg Cotton Mills, Malout. The allegations are therefore not confined to rendition of accounts or settlement of partnership disputes, but involve distinct criminal offences p 468, 471 and 120 12198 of 2026 -4- involved in any other criminal case. He petitioner is ready and willing to join investigation as and when called upon to do so by the investigating agency. these submissions learned senior counsel prays that the present petition be allowed and the petitioner be granted the anticipatory bail. Learned state counsel has filed status report in the matter and while relying upon the same, she has vehemently opposed the prayer of the petitioner for grant of bail and submitted that the offence committed by the petitioner is serious in nature and he does not deserve any concession from this Court. It is submitted that the dispute cannot be brushed aside as a mere civil or family disp investigation conducted by multiple Special Investigation Teams has revealed prima facie material demonstrating preparation and use of forged retirement deeds, misuse of signed blank papers and fraudulent exclusion of the complainant and her sons from the most valuable partnership concern, namely M/s Shri Ram Saroop Garg Cotton Mills, Malout. The allegations are therefore not confined to rendition of accounts or settlement of partnership disputes, but involve distinct criminal offences punishable under Sections 420, 467, 468, 471 and 120-B IPC. She submitted that the investigation involved in any other criminal case. He contends that the petitioner is ready and willing to join investigation as and when called upon to do so by the investigating agency. With or counsel prays that the present petition be allowed and the petitioner be granted the Learned state counsel has filed status report in the matter and while relying upon the same, she has vehemently the petitioner for grant of bail and submitted that the offence committed by the petitioner is serious in nature and he does not deserve any concession from It is submitted that the dispute cannot be brushed aside as a mere civil or family dispute inasmuch as the investigation conducted by multiple Special Investigation Teams has revealed prima facie material demonstrating preparation and use of forged retirement deeds, misuse of signed blank papers and fraudulent exclusion of the d her sons from the most valuable partnership concern, namely M/s Shri Ram Saroop Garg Cotton Mills, Malout. The allegations are therefore not confined to rendition of accounts or settlement of partnership disputes, but involve unishable under Sections 420, 467, submitted that the investigation that the petitioner is ready and willing to join investigation as and With or counsel prays that the present petition be allowed and the petitioner be granted the Learned state counsel has filed status report in the matter and while relying upon the same, she has vehemently the petitioner for grant of bail and submitted that the offence committed by the petitioner is serious in nature and he does not deserve any concession from It is submitted that the dispute cannot be brushed ute inasmuch as the investigation conducted by multiple Special Investigation Teams has revealed prima facie material demonstrating preparation and use of forged retirement deeds, misuse of signed blank papers and fraudulent exclusion of the d her sons from the most valuable partnership concern, namely M/s Shri Ram Saroop Garg Cotton Mills, Malout. The allegations are therefore not confined to rendition of accounts or settlement of partnership disputes, but involve unishable under Sections 420, 467, submitted that the investigation PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 specifically reveals that the petitioner was one of the founding partners of the firm and was directly connected with the execution of the disputed retirement d documents. between the versions of the present petitioner and co Vinod Garg and Satpal Garg regarding the alleged settlement and division of firms. Such contradictions clearly indica the documents were fabricated later to give colour of legitimacy to the fraudulent acts committed against the complainant. He further submitted that the petitioner did not appear before the Investigating Agency despite notices issued by the office Superintendent of Police, Malout, thereby clearly demonstrating non further argued that the petitioner’s conduct disentitles him from the discretionary relief of anticipatory bail. The custodial interrogatio original forged documents, to ascertain the complete modus operandi adopted by the accused persons, to identify the role of each conspirator and to trace the proceeds and assets wrongfully grabbed through fo prays that the present petition be dismissed. 5. Per contra, learned senior counsel appearing on behalf of the complainant/respondent No.2 12198 of 2026 -5- specifically reveals that the petitioner was one of the founding partners of the firm and was directly connected with the execution of the disputed retirement d documents. The SIT also noticed material contradictions between the versions of the present petitioner and co Vinod Garg and Satpal Garg regarding the alleged settlement and division of firms. Such contradictions clearly indica the documents were fabricated later to give colour of legitimacy to the fraudulent acts committed against the complainant. He further submitted that the petitioner did not appear before the Investigating Agency despite notices issued by the office Superintendent of Police, Malout, thereby clearly demonstrating non-cooperation with the investigation. It is further argued that the petitioner’s conduct disentitles him from the discretionary relief of anticipatory bail. The custodial interrogation of the petitioner is thus original forged documents, to ascertain the complete modus operandi adopted by the accused persons, to identify the role of each conspirator and to trace the proceeds and assets wrongfully grabbed through forged documents. prays that the present petition be dismissed. Per contra, learned senior counsel appearing on behalf of the complainant/respondent No.2 specifically reveals that the petitioner was one of the founding partners of the firm and was directly connected with the execution of the disputed retirement deeds and partnership The SIT also noticed material contradictions between the versions of the present petitioner and co-accused Vinod Garg and Satpal Garg regarding the alleged settlement and division of firms. Such contradictions clearly indicate that the documents were fabricated later to give colour of legitimacy to the fraudulent acts committed against the complainant. He further submitted that the petitioner did not appear before the Investigating Agency despite notices issued by the office of the Superintendent of Police, Malout, thereby clearly cooperation with the investigation. It is further argued that the petitioner’s conduct disentitles him from the discretionary relief of anticipatory bail. The custodial thus necessary to recover original forged documents, to ascertain the complete modus operandi adopted by the accused persons, to identify the role of each conspirator and to trace the proceeds and assets rged documents. Hence she prays that the present petition be dismissed. Per contra, learned senior counsel appearing on behalf of the complainant/respondent No.2 adopts the specifically reveals that the petitioner was one of the founding partners of the firm and was directly connected with the eeds and partnership The SIT also noticed material contradictions accused Vinod Garg and Satpal Garg regarding the alleged settlement te that the documents were fabricated later to give colour of legitimacy to the fraudulent acts committed against the complainant. He further submitted that the petitioner did not appear before the of the Superintendent of Police, Malout, thereby clearly cooperation with the investigation. It is further argued that the petitioner’s conduct disentitles him from the discretionary relief of anticipatory bail. The custodial necessary to recover original forged documents, to ascertain the complete modus operandi adopted by the accused persons, to identify the role of each conspirator and to trace the proceeds and assets Hence she Per contra, learned senior counsel appearing on adopts the PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 submissions made by learned state counsel and opposed the present pe petitioner is not entitled to the extraordinary relief of anticipatory bail in view of the serious and grave allegations of cheating, forgery, fabrication of valuable security and criminal conspiracy involving property several crores of rupees. Learned counsel further submitted that the petitioner has throughout played an active and conscious role in the conspiracy and cannot escape liability by merely claiming residence at Delhi or absence fro affairs. The SIT investigation has categorically recorded that the petitioner, in connivance with co procured stamp papers, prepared forged retirement deeds and facilitated fraudulent transfer of control over the complainant’s share in the firm. It is further submitted that the plea that earlier cancellation reports were filed is wholly misconceived and misleading. The said cancellation reports never attained finality and were repeatedly rejected or returned by the competent Co more than one occasion. The subsequent SIT investigations unearthed fresh incriminating material against the petitioner and specifically recommended his nomination as an accused along with addition of Section 1 petitioner cannot derive any advantage from earlier 12198 of 2026 -6- submissions made by learned state counsel and opposed the present petition and further petitioner is not entitled to the extraordinary relief of anticipatory bail in view of the serious and grave allegations of cheating, forgery, fabrication of valuable security and criminal conspiracy involving property and business assets worth several crores of rupees. Learned counsel further submitted that the petitioner has throughout played an active and conscious role in the conspiracy and cannot escape liability by merely claiming residence at Delhi or absence fro affairs. The SIT investigation has categorically recorded that the petitioner, in connivance with co procured stamp papers, prepared forged retirement deeds and facilitated fraudulent transfer of control over the complainant’s share in the firm. It is further submitted that the plea that earlier cancellation reports were filed is wholly misconceived and misleading. The said cancellation reports never attained finality and were repeatedly rejected or returned by the competent Courts, which directed further investigation on more than one occasion. The subsequent SIT investigations unearthed fresh incriminating material against the petitioner and specifically recommended his nomination as an accused along with addition of Section 120 petitioner cannot derive any advantage from earlier submissions made by learned state counsel and vehemently further submitted that the petitioner is not entitled to the extraordinary relief of anticipatory bail in view of the serious and grave allegations of cheating, forgery, fabrication of valuable security and criminal and business assets worth several crores of rupees. Learned counsel further submitted that the petitioner has throughout played an active and conscious role in the conspiracy and cannot escape liability by merely claiming residence at Delhi or absence from day-to-day affairs. The SIT investigation has categorically recorded that the petitioner, in connivance with co-accused persons, procured stamp papers, prepared forged retirement deeds and facilitated fraudulent transfer of control over the complainant’s share in the firm. It is further submitted that the plea that earlier cancellation reports were filed is wholly misconceived and misleading. The said cancellation reports never attained finality and were repeatedly rejected or returned by the urts, which directed further investigation on more than one occasion. The subsequent SIT investigations unearthed fresh incriminating material against the petitioner and specifically recommended his nomination as an accused 20-B IPC. Therefore, the petitioner cannot derive any advantage from earlier vehemently submitted that the petitioner is not entitled to the extraordinary relief of anticipatory bail in view of the serious and grave allegations of cheating, forgery, fabrication of valuable security and criminal and business assets worth several crores of rupees. Learned counsel further submitted that the petitioner has throughout played an active and conscious role in the conspiracy and cannot escape liability by day affairs. The SIT investigation has categorically recorded that accused persons, procured stamp papers, prepared forged retirement deeds and facilitated fraudulent transfer of control over the complainant’s share in the firm. It is further submitted that the plea that earlier cancellation reports were filed is wholly misconceived and misleading. The said cancellation reports never attained finality and were repeatedly rejected or returned by the urts, which directed further investigation on more than one occasion. The subsequent SIT investigations unearthed fresh incriminating material against the petitioner and specifically recommended his nomination as an accused B IPC. Therefore, the petitioner cannot derive any advantage from earlier PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 inconclusive reports. specifically records that the petitioner has been absconding and evading arrest and that repeated raids had to be conducted to secure his presence. petitioner has not approached this has selectively relied upon portions of earlier reports while suppressing subsequent findings and recommendations against him. Learned counsel furt because the dispute arises amongst family members would not dilute the criminality involved where forged and fabricated documents have been used to deprive legal heirs of their valuable business interests and properties. The Hon’b Supreme Court as well as this that economic offences involving deep forgery and misappropriation stand on a different footing and custodial interrogation is often indispensable for effective investigation. The allegations in the present systematic fraud concerning firms having turnover of hundreds of crores and therefore constitute grave economic offences affecting not merely private rights but the sanctity of commercial transactions and public records. submitted t proceedings pending before the Hon’ble Supreme Court concerning co 12198 of 2026 -7- inconclusive reports. The status report specifically records that the petitioner has been absconding and evading arrest and that repeated raids had to be ted to secure his presence. itioner has not approached this Court with clean hands and has selectively relied upon portions of earlier reports while suppressing subsequent findings and recommendations against him. Learned counsel further submitted that merely because the dispute arises amongst family members would not dilute the criminality involved where forged and fabricated documents have been used to deprive legal heirs of their valuable business interests and properties. The Hon’b Supreme Court as well as this Court have consistently held that economic offences involving deep forgery and misappropriation stand on a different footing and custodial interrogation is often indispensable for effective investigation. The allegations in the present systematic fraud concerning firms having turnover of hundreds of crores and therefore constitute grave economic offences affecting not merely private rights but the sanctity of commercial transactions and public records. submitted that the reliance placed by the petitioner on proceedings pending before the Hon’ble Supreme Court concerning co-accused persons is wholly misplaced. Any The status report filed by the state specifically records that the petitioner has been absconding and evading arrest and that repeated raids had to be ted to secure his presence. He argued that the Court with clean hands and has selectively relied upon portions of earlier reports while suppressing subsequent findings and recommendations her submitted that merely because the dispute arises amongst family members would not dilute the criminality involved where forged and fabricated documents have been used to deprive legal heirs of their valuable business interests and properties. The Hon’ble Court have consistently held that economic offences involving deep-rooted conspiracy, forgery and misappropriation stand on a different footing and custodial interrogation is often indispensable for effective investigation. The allegations in the present case involve systematic fraud concerning firms having turnover of hundreds of crores and therefore constitute grave economic offences affecting not merely private rights but the sanctity of commercial transactions and public records. It is also hat the reliance placed by the petitioner on proceedings pending before the Hon’ble Supreme Court accused persons is wholly misplaced. Any filed by the state specifically records that the petitioner has been absconding and evading arrest and that repeated raids had to be he Court with clean hands and has selectively relied upon portions of earlier reports while suppressing subsequent findings and recommendations her submitted that merely because the dispute arises amongst family members would not dilute the criminality involved where forged and fabricated documents have been used to deprive legal heirs of their e Court have consistently held rooted conspiracy, forgery and misappropriation stand on a different footing and custodial interrogation is often indispensable for effective case involve systematic fraud concerning firms having turnover of hundreds of crores and therefore constitute grave economic offences affecting not merely private rights but the sanctity of It is also hat the reliance placed by the petitioner on proceedings pending before the Hon’ble Supreme Court accused persons is wholly misplaced. Any PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 interim protection granted in mediation proceedings cannot automatically confer a right of anticipatory petitioner, particularly when the allegations and role attributed to him are distinct and when investigation against him is still incomplete. of the petitioner in preparation of forged d evasive conduct during investigation, the requirement of custodial interrogation and the prima facie evidence collected during investigation, learned counsel prayed that the present petition being devoid of merit deserves to be dismissed. 6. Having heard learned counsel for the parties and after perusing the Court is of the considered opinion that the petitioner has failed to make out a case for grant of the extraordinary concession of anticipator cannot, at this stage, be brushed aside as a mere civil dispute arising out of family settlement or rendition of partnership accounts. Rather, the material collected during investigation prima facie discl preparation and use of forged and fabricated retirement deeds allegedly executed on behalf of the complainant and her sons for the purpose of unlawfully excluding them from the partnership concern and usurping their 12198 of 2026 -8- interim protection granted in mediation proceedings cannot automatically confer a right of anticipatory petitioner, particularly when the allegations and role attributed to him are distinct and when investigation against him is still incomplete. In view of the gravity of allegations, the active role of the petitioner in preparation of forged d evasive conduct during investigation, the requirement of custodial interrogation and the prima facie evidence collected during investigation, learned counsel prayed that the present petition being devoid of merit deserves to be dismissed. Having heard learned counsel for the parties and after perusing the paperbook and reply filed by the state Court is of the considered opinion that the petitioner has failed to make out a case for grant of the extraordinary concession of anticipatory bail. The allegations levelled in the present FIR cannot, at this stage, be brushed aside as a mere civil dispute arising out of family settlement or rendition of partnership accounts. Rather, the material collected during investigation prima facie discloses a well-planned conspiracy involving preparation and use of forged and fabricated retirement deeds allegedly executed on behalf of the complainant and her sons for the purpose of unlawfully excluding them from the partnership concern and usurping their interim protection granted in mediation proceedings cannot automatically confer a right of anticipatory bail upon the petitioner, particularly when the allegations and role attributed to him are distinct and when investigation against him is still In view of the gravity of allegations, the active role of the petitioner in preparation of forged documents, his evasive conduct during investigation, the requirement of custodial interrogation and the prima facie evidence collected during investigation, learned counsel prayed that the present petition being devoid of merit deserves to be dismissed. Having heard learned counsel for the parties and paperbook and reply filed by the state, this Court is of the considered opinion that the petitioner has failed to make out a case for grant of the extraordinary concession of y bail. The allegations levelled in the present FIR cannot, at this stage, be brushed aside as a mere civil dispute arising out of family settlement or rendition of partnership accounts. Rather, the material collected during investigation planned conspiracy involving preparation and use of forged and fabricated retirement deeds allegedly executed on behalf of the complainant and her sons for the purpose of unlawfully excluding them from the partnership concern and usurping their valuable share in the interim protection granted in mediation proceedings cannot bail upon the petitioner, particularly when the allegations and role attributed to him are distinct and when investigation against him is still In view of the gravity of allegations, the active role ocuments, his evasive conduct during investigation, the requirement of custodial interrogation and the prima facie evidence collected during investigation, learned counsel prayed that the present Having heard learned counsel for the parties and , this Court is of the considered opinion that the petitioner has failed to make out a case for grant of the extraordinary concession of y bail. The allegations levelled in the present FIR cannot, at this stage, be brushed aside as a mere civil dispute arising out of family settlement or rendition of partnership accounts. Rather, the material collected during investigation planned conspiracy involving preparation and use of forged and fabricated retirement deeds allegedly executed on behalf of the complainant and her sons for the purpose of unlawfully excluding them from the valuable share in the PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 business and assets of the firm. The offences alleged against the petitioner are serious in nature and include offences punishable under Sections 420, 467, 468, 471 and 120 which relate to cheating, forgery of valuable securit criminal conspiracy. Merely because certain cancellation reports had earlier been submitted would not entitle the petitioner to anticipatory bail, particularly when such reports admittedly never attained finality and were not accepted by the competent Courts, which instead directed further investigation. The subsequent investigation has allegedly unearthed fresh incriminating material and specifically recommended the nomination of the present petitioner as an accused along with addition of Section 120 contention raised on behalf of the petitioner that he is a senior citizen residing at Delhi and was not actively involved in the day-to-day affairs of the firms also does not persuade this Court at this stage, inasmuch as the investigation prim suggests his active participation in the execution of the disputed documents and the conspiracy alleged by the prosecution. Furthermore, the record reflects that despite issuance of notices by the investigating agency, the petitioner did not join i forgery, fabrication of original documents and deep economic conspiracy, custodial interrogation assumes 12198 of 2026 -9- business and assets of the firm. The offences alleged against the petitioner are serious in nature and include offences punishable under Sections 420, 467, 468, 471 and 120 which relate to cheating, forgery of valuable securit criminal conspiracy. Merely because certain cancellation reports had earlier been submitted would not entitle the petitioner to anticipatory bail, particularly when such reports admittedly never attained finality and were not accepted by the t Courts, which instead directed further investigation. The subsequent investigation has allegedly unearthed fresh incriminating material and specifically recommended the nomination of the present petitioner as an accused along with addition of Section 120 contention raised on behalf of the petitioner that he is a senior citizen residing at Delhi and was not actively involved in the day affairs of the firms also does not persuade this Court at this stage, inasmuch as the investigation prim suggests his active participation in the execution of the disputed documents and the conspiracy alleged by the prosecution. Furthermore, the record reflects that despite issuance of notices by the investigating agency, the petitioner did not join investigation. In cases involving allegations of forgery, fabrication of original documents and deep economic conspiracy, custodial interrogation assumes business and assets of the firm. The offences alleged against the petitioner are serious in nature and include offences punishable under Sections 420, 467, 468, 471 and 120-B IPC, which relate to cheating, forgery of valuable security and criminal conspiracy. Merely because certain cancellation reports had earlier been submitted would not entitle the petitioner to anticipatory bail, particularly when such reports admittedly never attained finality and were not accepted by the t Courts, which instead directed further investigation. The subsequent investigation has allegedly unearthed fresh incriminating material and specifically recommended the nomination of the present petitioner as an accused along with addition of Section 120-B IPC. The contention raised on behalf of the petitioner that he is a senior citizen residing at Delhi and was not actively involved in the day affairs of the firms also does not persuade this Court at this stage, inasmuch as the investigation prima facie suggests his active participation in the execution of the disputed documents and the conspiracy alleged by the prosecution. Furthermore, the record reflects that despite issuance of notices by the investigating agency, the petitioner nvestigation. In cases involving allegations of forgery, fabrication of original documents and deep-rooted economic conspiracy, custodial interrogation assumes business and assets of the firm. The offences alleged against the petitioner are serious in nature and include offences B IPC, y and criminal conspiracy. Merely because certain cancellation reports had earlier been submitted would not entitle the petitioner to anticipatory bail, particularly when such reports admittedly never attained finality and were not accepted by the t Courts, which instead directed further investigation. The subsequent investigation has allegedly unearthed fresh incriminating material and specifically recommended the nomination of the present petitioner as an The contention raised on behalf of the petitioner that he is a senior citizen residing at Delhi and was not actively involved in the day affairs of the firms also does not persuade this a facie suggests his active participation in the execution of the disputed documents and the conspiracy alleged by the prosecution. Furthermore, the record reflects that despite issuance of notices by the investigating agency, the petitioner nvestigation. In cases involving allegations of rooted economic conspiracy, custodial interrogation assumes PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 significance for the purpose of recovery of original records, discovery of the manner in which t prepared and executed, identification of the role played by each conspirator and tracing of the benefits allegedly derived from the fraudulent transactions. At this stage, this Court cannot conclusively record findings on the merit claims; however, the material collected during investigation is sufficient to prima facie indicate the involvement of the petitioner in the alleged offences. that while considering a plea for grant of anticipatory Court has to equilibrate between safeguarding individual rights and protecting societal interest(s). The Court ought to reckon with the magnitude and nature of the offence; the role attributed to the accused; the need for fair and free investigation as also the deeper and wide impact of such alleged iniquities on the society. It would be apposite to refer herein judgment of Hon’ble Supreme Court in Sharma’, (1997) 7 SCC 187 under: "6. We find, force in the submission of CBI that custodial interrogation is qualitatively more elicitation well 12198 of 2026 -10- significance for the purpose of recovery of original records, discovery of the manner in which the forged documents were prepared and executed, identification of the role played by each conspirator and tracing of the benefits allegedly derived from the fraudulent transactions. At this stage, this Court cannot conclusively record findings on the merit claims; however, the material collected during investigation is sufficient to prima facie indicate the involvement of the petitioner in the alleged offences. It is befitting to mention here that while considering a plea for grant of anticipatory Court has to equilibrate between safeguarding individual rights and protecting societal interest(s). The Court ought to reckon with the magnitude and nature of the offence; the role attributed to the accused; the need for fair and free tion as also the deeper and wide impact of such alleged iniquities on the society. It would be apposite to refer herein judgment of Hon’ble Supreme Court in Sharma’, (1997) 7 SCC 187, wherein it has been held as "6. We find, force in the submission of CBI that custodial interrogation is qualitatively more elicitation-oriented than questioning a suspect who is well-ensconced with a favourable order under Section significance for the purpose of recovery of original records, he forged documents were prepared and executed, identification of the role played by each conspirator and tracing of the benefits allegedly derived from the fraudulent transactions. At this stage, this Court cannot conclusively record findings on the merits of rival claims; however, the material collected during investigation is sufficient to prima facie indicate the involvement of the It is befitting to mention here that while considering a plea for grant of anticipatory bail, the Court has to equilibrate between safeguarding individual rights and protecting societal interest(s). The Court ought to reckon with the magnitude and nature of the offence; the role attributed to the accused; the need for fair and free tion as also the deeper and wide impact of such alleged iniquities on the society. It would be apposite to refer herein judgment of Hon’ble Supreme Court in ‘State Vs. Anil , wherein it has been held as "6. We find, force in the submission of CBI that custodial interrogation is qualitatively more oriented than questioning a suspect who is ensconced with a favourable order under Section significance for the purpose of recovery of original records, he forged documents were prepared and executed, identification of the role played by each conspirator and tracing of the benefits allegedly derived from the fraudulent transactions. At this stage, this Court s of rival claims; however, the material collected during investigation is sufficient to prima facie indicate the involvement of the It is befitting to mention here bail, the Court has to equilibrate between safeguarding individual rights and protecting societal interest(s). The Court ought to reckon with the magnitude and nature of the offence; the role attributed to the accused; the need for fair and free tion as also the deeper and wide impact of such alleged iniquities on the society. It would be apposite to refer ‘State Vs. Anil , wherein it has been held as "6. We find, force in the submission of CBI that custodial interrogation is qualitatively more oriented than questioning a suspect who is ensconced with a favourable order under Section PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 438 of the Code. In a case like this, effective inter advantage in disinterring many useful information and also materials which would have been concealed. Success in such interrogation would elude if the suspected person knows that he is well protected and insu during the time he is interrogated. Very often interrogation in such a condition would reduce to a mere ritual. The argument that the custodial interrogation is fraught with the danger of the person being subjected to third countenanced, for, such an argument can be advanced by all accused in all criminal cases. The Court has to presume that responsible police officers would conduct themselves in a responsible manner and that those entrusted with t offences would not conduct themselves as offenders." 7. The Hon'ble Supreme Court, in case titled as Chidambaram v. Directorate of Enforcement", (2019) 9 SCC 24, while dealing with economic offences, has held that the power of 12198 of 2026 -11- 438 of the Code. In a case like this, effective interrogation of a suspected person is of tremendous advantage in disinterring many useful information and also materials which would have been concealed. Success in such interrogation would elude if the suspected person knows that he is well protected and insulated by a pre during the time he is interrogated. Very often interrogation in such a condition would reduce to a mere ritual. The argument that the custodial interrogation is fraught with the danger of the person being subjected to third degree methods need not be countenanced, for, such an argument can be advanced by all accused in all criminal cases. The Court has to presume that responsible police officers would conduct themselves in a responsible manner and that those entrusted with t offences would not conduct themselves as offenders." The Hon'ble Supreme Court, in case titled as Chidambaram v. Directorate of Enforcement", (2019) 9 , while dealing with economic offences, has held that the power of anticipatory bail should be sparingly exercised in 438 of the Code. In a case like this, effective rogation of a suspected person is of tremendous advantage in disinterring many useful information and also materials which would have been concealed. Success in such interrogation would elude if the suspected person knows that he is well lated by a pre-arrest bail order during the time he is interrogated. Very often interrogation in such a condition would reduce to a mere ritual. The argument that the custodial interrogation is fraught with the danger of the person degree methods need not be countenanced, for, such an argument can be advanced by all accused in all criminal cases. The Court has to presume that responsible police officers would conduct themselves in a responsible manner and that those entrusted with the task of disinterring offences would not conduct themselves as offenders." The Hon'ble Supreme Court, in case titled as "P. Chidambaram v. Directorate of Enforcement", (2019) 9 , while dealing with economic offences, has held that anticipatory bail should be sparingly exercised in 438 of the Code. In a case like this, effective rogation of a suspected person is of tremendous advantage in disinterring many useful information and also materials which would have been concealed. Success in such interrogation would elude if the suspected person knows that he is well arrest bail order during the time he is interrogated. Very often interrogation in such a condition would reduce to a mere ritual. The argument that the custodial interrogation is fraught with the danger of the person degree methods need not be countenanced, for, such an argument can be advanced by all accused in all criminal cases. The Court has to presume that responsible police officers would conduct themselves in a responsible manner he task of disinterring "P. Chidambaram v. Directorate of Enforcement", (2019) 9 , while dealing with economic offences, has held that anticipatory bail should be sparingly exercised in PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 economic offences. The relevant portion of the judgment is reproduced as under: "77. After referring to Siddharam Satlingappa Mhetre and other judgments and observing that anticipatory bail can be grante circumstances, in Bihar para 19) Economic Offences 78. Power under Section 438 CrPC being an extraordinary remedy, has to be exercised sparingly; more so, in cases of economic offences. Economic offences stand as a different class as they affect the 12198 of 2026 -12- economic offences. The relevant portion of the judgment is reproduced as under:- "77. After referring to Siddharam Satlingappa Mhetre and other judgments and observing that anticipatory bail can be granted only in exceptional circumstances, in Jai Prakash Singh v. State of Bihar, the Supreme Court held as under: (SCC p.386, para 19) "19. Parameters for grant of anticipatory bail in a serious offence are required to be satisfied and further while granting s must record the reasons therefor. Anticipatory bail can be granted only in exceptional circumstances where the Court is prima facie of the view that the applicant has falsely been enroped in the crime and would not misuse his liberty”. Economic Offences 78. Power under Section 438 CrPC being an extraordinary remedy, has to be exercised sparingly; more so, in cases of economic offences. Economic offences stand as a different class as they affect the economic offences. The relevant portion of the judgment is "77. After referring to Siddharam Satlingappa Mhetre and other judgments and observing that anticipatory d only in exceptional Jai Prakash Singh v. State of , the Supreme Court held as under: (SCC p.386, "19. Parameters for grant of anticipatory bail in a serious offence are required to be satisfied and further while granting such relief, the court must record the reasons therefor. Anticipatory bail can be granted only in exceptional circumstances where the Court is prima facie of the view that the applicant has falsely been enroped in the crime and would not misuse his 78. Power under Section 438 CrPC being an extraordinary remedy, has to be exercised sparingly; more so, in cases of economic offences. Economic offences stand as a different class as they affect the economic offences. The relevant portion of the judgment is "77. After referring to Siddharam Satlingappa Mhetre and other judgments and observing that anticipatory d only in exceptional Jai Prakash Singh v. State of , the Supreme Court held as under: (SCC p.386, "19. Parameters for grant of anticipatory bail in a serious offence are required to be satisfied uch relief, the court must record the reasons therefor. Anticipatory bail can be granted only in exceptional circumstances where the Court is prima facie of the view that the applicant has falsely been enroped in the crime and would not misuse his 78. Power under Section 438 CrPC being an extraordinary remedy, has to be exercised sparingly; more so, in cases of economic offences. Economic offences stand as a different class as they affect the PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 economic fabric of the society. In Enforcement v. Ashok Kumar Jain that in economic offences, the accuse is not entitled to anticipatory bail. XXX XXX XXX 83. Grant of anticipatory bail at the stage of investigation may frustrate the investigating agency in interro useful information and also the materials which might have been concealed. Success in such interrogation would elude if the accused knows that he is protected by the order of the court. Grant of anticipatory bail, p would definitely hamper the effective investigation. Having regard to the materials said to have been collected by the respondent Enforcement Directorate and considering the stage of the investigation, we are of the view th anticipatory bail”. 8. Considering the seriousness of allegations, the nature of evidence collected, the requirement of further investigation and custodial interrogation, and the conduct 12198 of 2026 -13- economic fabric of the society. In Enforcement v. Ashok Kumar Jain that in economic offences, the accuse is not entitled to anticipatory bail. XXX XXX XXX 83. Grant of anticipatory bail at the stage of investigation may frustrate the investigating agency in interrogating the accused and in collecting the useful information and also the materials which might have been concealed. Success in such interrogation would elude if the accused knows that he is protected by the order of the court. Grant of anticipatory bail, particularly in economic offences would definitely hamper the effective investigation. Having regard to the materials said to have been collected by the respondent Enforcement Directorate and considering the stage of the investigation, we are of the view that it is not a fit case to grant anticipatory bail”. Considering the seriousness of allegations, the nature of evidence collected, the requirement of further investigation and custodial interrogation, and the conduct economic fabric of the society. In Directorate of Enforcement v. Ashok Kumar Jain, it was held that in economic offences, the accuse is not entitled to 83. Grant of anticipatory bail at the stage of investigation may frustrate the investigating agency gating the accused and in collecting the useful information and also the materials which might have been concealed. Success in such interrogation would elude if the accused knows that he is protected by the order of the court. Grant of articularly in economic offences would definitely hamper the effective investigation. Having regard to the materials said to have been collected by the respondent Enforcement Directorate and considering the stage of the investigation, we are at it is not a fit case to grant Considering the seriousness of allegations, the nature of evidence collected, the requirement of further investigation and custodial interrogation, and the conduct rectorate of , it was held that in economic offences, the accuse is not entitled to 83. Grant of anticipatory bail at the stage of investigation may frustrate the investigating agency gating the accused and in collecting the useful information and also the materials which might have been concealed. Success in such interrogation would elude if the accused knows that he is protected by the order of the court. Grant of articularly in economic offences would definitely hamper the effective investigation. Having regard to the materials said to have been collected by the respondent Enforcement Directorate and considering the stage of the investigation, we are at it is not a fit case to grant Considering the seriousness of allegations, the nature of evidence collected, the requirement of further investigation and custodial interrogation, and the conduct PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment CRM-M-12198 attributed to the petitioner, this exercise its discretionary jurisdiction under Section 2023 in favour of the petitioner. 9. Consequently, the present petition being devoid of merit is hereby dismissed. 10. Needless to add, nothing observed be construed as an expression of opinion on the merits of the case. 18.05.202 Puneet…. Whether speaking/reasoned Whether reportable 12198 of 2026 -14- attributed to the petitioner, this Court is not inclined to exercise its discretionary jurisdiction under Section in favour of the petitioner. Consequently, the present petition being devoid of merit is hereby dismissed. Needless to add, nothing observed be construed as an expression of opinion on the merits of the (RUPINDERJIT CHAHAL) .2026 Whether speaking/reasoned : Whether reportable : Court is not inclined to exercise its discretionary jurisdiction under Section 482 BNSS, Consequently, the present petition being devoid of Needless to add, nothing observed hereinabove shall be construed as an expression of opinion on the merits of the (RUPINDERJIT CHAHAL) JUDGE : Yes/No : Yes/No Court is not inclined to 482 BNSS, Consequently, the present petition being devoid of hereinabove shall be construed as an expression of opinion on the merits of the PUNEET SHARMA 2026.05.19 09.34 I attest to the accuracy and authenticity of this order/judgment