CRM-M- IN THE HIGH COURT OF PUNJAB AND HARYANA AT 210 Bare Khan State of Punjab and another Date of decision: Date of Uploading : 2 CORAM: Present: SUMEET GOEL 1. BNSS, 2023 seeking cancellation of anticipatory bail granted to respondent No.2 vide order dated 31.01.2026 (Annexure P Sessions Judge, for offences punishable under Section of the Immigration Act at Police Station Amloh, District Fatehgarh 2. Judge, Fatehgarh Sahib -9898-2026 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Bare Khan V/s State of Punjab and another Date of decision: 28.07.2026 Date of Uploading : 29.07.2026 CORAM: HON’BLE MR. JUSTICE SUMEET GOEL Mr. Nakul Sharma, Advocate for the petitioner. Mr. Jaypreet Singh, DAG Punjab. Mr. G.S. Ghuman, Advocate for respondent No.2. ***** SUMEET GOEL, J. (Oral) Present petition has been filed under BNSS, 2023 seeking cancellation of anticipatory bail granted to respondent No.2 vide order dated 31.01.2026 (Annexure P Sessions Judge, Fatehgarh Sahib in FIR No. for offences punishable under Sections 406 and 420 of IPC and Section 24 of the Immigration Act at Police Station Amloh, District Fatehgarh The relevant portion of the order passed by Fatehgarh Sahib, reads as under: “8.……… The net result of the entire discussion is that no logical purpose is to be served by compelling the accused to custodial interrogation. Hence, the accused is admitted to the concession of anticipatory bail with the condition to a period of four working days from today, with further condition that he shall comply with all the conditions of Section 482 BNSS. As and when he joins the investigation, the IO shall release him on anticipatory bail. In 1 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CRM-M-9898-2026 ....Petitioner ....Respondents HON’BLE MR. JUSTICE SUMEET GOEL Mr. Nakul Sharma, Advocate for the petitioner. Mr. Jaypreet Singh, DAG Punjab. Mr. G.S. Ghuman, Advocate for respondent No.2. Present petition has been filed under Section 483(3) of the BNSS, 2023 seeking cancellation of anticipatory bail granted to respondent No.2 vide order dated 31.01.2026 (Annexure P-2) passed by Additional in FIR No.21 dated 21.01.2026 registered 406 and 420 of IPC and Section 24 of the Immigration Act at Police Station Amloh, District Fatehgarh Sahib. The relevant portion of the order passed by Additional Sessions ……… The net result of the entire discussion is that no logical purpose is to be served by compelling the accused to custodial interrogation. Hence, the accused is admitted to the concession of anticipatory bail with the condition to appear before the IO within a period of four working days from today, with further condition that he shall comply with all the conditions of Section 482 BNSS. As and when he joins the investigation, the IO shall release him on anticipatory bail. In Section 483(3) of the BNSS, 2023 seeking cancellation of anticipatory bail granted to respondent Additional registered 406 and 420 of IPC and Section 24 . Sessions ……… The net result of the entire discussion is that no logical purpose is to be served by compelling the accused to custodial interrogation. Hence, the accused is admitted to the concession of ppear before the IO within a period of four working days from today, with further condition that he shall comply with all the conditions of Section 482 BNSS. As and when he joins the investigation, the IO shall release him on anticipatory bail. In AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- 3. below has passed the said appreciating the seriousness and gravity of the allegations illegal, arbitrary and contrary to the settled principles governing grant of anticipatory bail. has failed to appreciate t respondent No.2 United States of America, dishonestly induced the complainant to part with an amount of while the remaining amount of been further contended been involved in several criminal cases of a similar nature criminal ante below, the same were completely ignored while extending the concession of anticipatory bail. According to to appreciate that necessary not only for recovery of the remaining cheated amount but also for tracing the money trail, identifying other persons involved in the transaction and carrying out an effective and fair investigation. It further contended that the custodial interrogation -9898-2026 the event of non compliance with directions issued vide this order, the Investigating Officer may proceed as per law. Accordingly, the anticipatory bail application is allowed. Nothing expressed herein shall be construed as an expression on the merits of the c application be consigned to record after due compliance.” Learned counsel for the petitioner has iterated that the Court below has passed the said impugned order appreciating the seriousness and gravity of the allegations illegal, arbitrary and contrary to the settled principles governing grant of anticipatory bail. Learned counsel has further iterated failed to appreciate the seriousness and gravity of the allegations against respondent No.2 who under false assurances to secure employment in United States of America, dishonestly induced the complainant to part with an amount of ₹50,00,000/-, out of which only while the remaining amount of ₹30,00,000/ been further contended that respondent No.2 is a habitual offender and has been involved in several criminal cases of a similar nature criminal antecedents having been brought to the notice of the learned Court below, the same were completely ignored while extending the concession of anticipatory bail. According to learned counsel, to appreciate that the custodial interrogat necessary not only for recovery of the remaining cheated amount but also for tracing the money trail, identifying other persons involved in the transaction and carrying out an effective and fair investigation. It contended that the Court below has custodial interrogation of respondent No.2 2 ent of non compliance with directions issued vide this order, the Investigating Officer may proceed as per law. Accordingly, the anticipatory bail application is allowed. Nothing expressed herein shall be construed as an expression on the merits of the case. Papers of bail application be consigned to record-room (Sessions), Fatehgarh Sahib, Learned counsel for the petitioner has iterated that the Court impugned order in a mechanical manner without appreciating the seriousness and gravity of the allegations and the same illegal, arbitrary and contrary to the settled principles governing grant of Learned counsel has further iterated that the Court below he seriousness and gravity of the allegations against who under false assurances to secure employment in United States of America, dishonestly induced the complainant to part with , out of which only ₹20,00,000/- was returned, 30,00,000/- is still to be recovered. It has that respondent No.2 is a habitual offender and has been involved in several criminal cases of a similar nature and despite his cedents having been brought to the notice of the learned Court below, the same were completely ignored while extending the concession of learned counsel, the Court below has failed custodial interrogation of respondent No.2 was necessary not only for recovery of the remaining cheated amount but also for tracing the money trail, identifying other persons involved in the transaction and carrying out an effective and fair investigation. It has been has mechanically observed that of respondent No.2 was not necessary without ent of non compliance with directions issued vide this order, the Investigating Officer may proceed as per law. Accordingly, the anticipatory bail application is allowed. Nothing expressed herein shall ase. Papers of bail room (Sessions), Fatehgarh Sahib, Learned counsel for the petitioner has iterated that the Court in a mechanical manner without and the same is illegal, arbitrary and contrary to the settled principles governing grant of that the Court below he seriousness and gravity of the allegations against the United States of America, dishonestly induced the complainant to part with was returned, has that respondent No.2 is a habitual offender and has espite his cedents having been brought to the notice of the learned Court below, the same were completely ignored while extending the concession of failed ion of respondent No.2 was necessary not only for recovery of the remaining cheated amount but also for tracing the money trail, identifying other persons involved in the has been the necessary without AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- considering the peculiar facts of the present case prejudice the contended bail by threatening and intimidating the complainant and his family members with dire consequences impugned order has been passed without application of mind. Thus, keeping in view the gravity of offence granted to respondent No.2 is entreated for. 4. way of affidavit of Gurdeep Singh, PPS, Deputy Superintendent of Police, Sub-division Amloh, District Fatehgarh Sahib tandem with the said status report; relevant whereof reads as under: -9898-2026 considering the peculiar facts of the present case prejudice the investigation at its very inception. Learned counsel contended that respondent No.2 has misused the concession of anticipatory bail by threatening and intimidating the complainant and his family members with dire consequences. It has been furth impugned order has been passed without application of mind. Thus, eeping in view the gravity of offence, cancellation of the anticipatory bail granted to respondent No.2 is entreated for. Learned State counsel has filed way of affidavit of Gurdeep Singh, PPS, Deputy Superintendent of Police, division Amloh, District Fatehgarh Sahib tandem with the said status report; relevant whereof reads as under: “9. That it is further submitted that during the course of inquiry and investigation, no material has come on record to indicate that any person extended any threat or intimidation to the complainant Bare Khan (present petitioner) with respect to the present case. The allegations regarding threat as mentioned in the present petition have not been found substantiated from the police record at this stage of investigation. Role of the Accused/Respondent No.2 10. That respondent No.2 Rajiv Kumar @ Rajiv Verma played a dir role in inducing the complainant Bare Khan (present petitioner) to part with a total amount of Rs.50 lakhs on the representation that he would send the complainant to the United States of America through proper channels. During inquiry, it surfaced th licensed immigration agent under the Immigration Act, yet he represented himself as capable of arranging immigration abroad and thereby dishonestly obtained the said amount from the complainant in the presence of Tarandeep Singh and Harjinder amount, respondent No.2 returned Rs.20 lakhs but retained Rs.30 lakhs and neither arranged the immigration nor returned the passport and other documents of the complainant. 3 considering the peculiar facts of the present case which has seriously investigation at its very inception. Learned counsel has further that respondent No.2 has misused the concession of anticipatory bail by threatening and intimidating the complainant and his family It has been further argued that the impugned order has been passed without application of mind. Thus, cancellation of the anticipatory bail granted to respondent No.2 is entreated for. Learned State counsel has filed short reply dated 10.03.2026 by way of affidavit of Gurdeep Singh, PPS, Deputy Superintendent of Police, division Amloh, District Fatehgarh Sahib and has raised submissions in tandem with the said status report; relevant whereof reads as under: further submitted that during the course of inquiry and investigation, no material has come on record to indicate that any person extended any threat or intimidation to the complainant Bare Khan (present petitioner) with respect to the present case. The llegations regarding threat as mentioned in the present petition have not been found substantiated from the police record at this stage of Role of the Accused/Respondent No.2 That respondent No.2 Rajiv Kumar @ Rajiv Verma played a dir role in inducing the complainant Bare Khan (present petitioner) to part with a total amount of Rs.50 lakhs on the representation that he would send the complainant to the United States of America through proper channels. During inquiry, it surfaced that respondent No.2 was not a licensed immigration agent under the Immigration Act, yet he represented himself as capable of arranging immigration abroad and thereby dishonestly obtained the said amount from the complainant in the h and Harjinder Singh. Out of the said amount, respondent No.2 returned Rs.20 lakhs but retained Rs.30 lakhs and neither arranged the immigration nor returned the passport and other documents of the complainant. seriously further that respondent No.2 has misused the concession of anticipatory bail by threatening and intimidating the complainant and his family er argued that the impugned order has been passed without application of mind. Thus, cancellation of the anticipatory bail y dated 10.03.2026 by way of affidavit of Gurdeep Singh, PPS, Deputy Superintendent of Police, and has raised submissions in further submitted that during the course of inquiry and investigation, no material has come on record to indicate that any person extended any threat or intimidation to the complainant Bare Khan (present petitioner) with respect to the present case. The llegations regarding threat as mentioned in the present petition have not been found substantiated from the police record at this stage of That respondent No.2 Rajiv Kumar @ Rajiv Verma played a direct role in inducing the complainant Bare Khan (present petitioner) to part with a total amount of Rs.50 lakhs on the representation that he would send the complainant to the United States of America through proper at respondent No.2 was not a licensed immigration agent under the Immigration Act, yet he represented himself as capable of arranging immigration abroad and thereby dishonestly obtained the said amount from the complainant in the Singh. Out of the said amount, respondent No.2 returned Rs.20 lakhs but retained Rs.30 lakhs and neither arranged the immigration nor returned the passport and AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- . 5. that the present petition make out any grounds that would warrant cancellation of anticipatory bail already granted by the Court below. Furthermore, the order granting anticipatory bail is a well reasoned and speaking order which has be passed after considering the material placed before the Court. According to learned counsel, the respondent No.2 has cooperated fully with the investigation and no supervening circumstances or misuse of liberty have been shown by the petitioner. On th dismissal of the instant petition is prayed for. 6. perused the record. 7. this Court CRM-M-9029 under:- -9898-2026 xxx xxx xxx xxx Learned counsel appearing for respondent No.2 has iterated that the present petition has been misconceived as the petitioner has failed to make out any grounds that would warrant cancellation of anticipatory bail already granted by the Court below. Furthermore, the order granting anticipatory bail is a well reasoned and speaking order which has be passed after considering the material placed before the Court. According to learned counsel, the respondent No.2 has cooperated fully with the investigation and no supervening circumstances or misuse of liberty have been shown by the petitioner. On the strength of these submissions, the dismissal of the instant petition is prayed for. I have heard learned counsel for the rival parties and have perused the record. It would be apposite to refer herein to a judgment passed by this Court titled as Dinesh Madan vs. State of Haryana and another 9029-2023, decided on 17.05.2024; “12. The concept of “cancellation of bail” is statutorily manifested terms of Section 439 (2) of 1973 Code. This concept was embodied in the earlier statute i.e. 1898 Code as well decidendi of judgment in case of Gurcharan Singh that, in the 1898 Code, the bail granted by the High Court could be cancelled only by it & bail granted by a Sessions Court could be cancelled by such Sessions Court only. However, Section 439(2) of 1973 Code has vested power to cancel bail which has been granted “ the High Court as also the Sessions Court. The words “ relates to Chapter XXXIII of Cr.P.C. of 1973 & hence the unequivocal result thereof is that the High Court as also the Sessions Court have requisite powers to cancel “any bail” granted by “any Court” by way of powers 4 xxx xxx xxx xxx” Learned counsel appearing for respondent No.2 has iterated misconceived as the petitioner has failed to make out any grounds that would warrant cancellation of anticipatory bail already granted by the Court below. Furthermore, the order granting anticipatory bail is a well reasoned and speaking order which has be passed after considering the material placed before the Court. According to learned counsel, the respondent No.2 has cooperated fully with the investigation and no supervening circumstances or misuse of liberty have e strength of these submissions, the dismissal of the instant petition is prayed for. I have heard learned counsel for the rival parties and have It would be apposite to refer herein to a judgment passed by Dinesh Madan vs. State of Haryana and another , decided on 17.05.2024; relevant whereof reads as cancellation of bail” is statutorily manifested terms of Section 439 (2) of 1973 Code. This concept was embodied in the earlier statute i.e. 1898 Code as well albeit with difference(s). The ratio Gurcharan Singh (supra) makes it clear l granted by the High Court could be cancelled only by it & bail granted by a Sessions Court could be cancelled by such Sessions Court only. However, Section 439(2) of 1973 Code has vested bail which has been granted “under this chapter” upon both the High Court as also the Sessions Court. The words “under this Chapter” relates to Chapter XXXIII of Cr.P.C. of 1973 & hence the unequivocal result thereof is that the High Court as also the Sessions Court have requisite ail” granted by “any Court” by way of powers Learned counsel appearing for respondent No.2 has iterated misconceived as the petitioner has failed to make out any grounds that would warrant cancellation of anticipatory bail already granted by the Court below. Furthermore, the order granting anticipatory bail is a well reasoned and speaking order which has been passed after considering the material placed before the Court. According to learned counsel, the respondent No.2 has cooperated fully with the investigation and no supervening circumstances or misuse of liberty have e strength of these submissions, the I have heard learned counsel for the rival parties and have It would be apposite to refer herein to a judgment passed by Dinesh Madan vs. State of Haryana and another in relevant whereof reads as cancellation of bail” is statutorily manifested in terms of Section 439 (2) of 1973 Code. This concept was embodied in the with difference(s). The ratio (supra) makes it clear l granted by the High Court could be cancelled only by it & bail granted by a Sessions Court could be cancelled by such Sessions Court only. However, Section 439(2) of 1973 Code has vested pon both under this Chapter” relates to Chapter XXXIII of Cr.P.C. of 1973 & hence the unequivocal result thereof is that the High Court as also the Sessions Court have requisite ail” granted by “any Court” by way of powers AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- -9898-2026 vested under this Chapter. In other words; the High Court is well empowered to cancel a bail granted by itself or by a Sessions Court or by the Court of a Magistrate while the Sessions Court is empowered to can granted by High Court or by itself or by a Magistrate. However, a Sessions Court can cancel bail granted by High Court only on account of supervening/new circumstances or on account of misconduct of such accused or on account of violation of any condition(s) imposed by the High Court while granting bail. The Magistrate can, of course, cancel bail granted by him but he cannot cancel a bail granted by High Court or Sessions Court except when such accused has violated/ imposed upon by such High Court or Sessions Court while granting bail to such accused. This position, is indubitable, as a Magistrate has been vested with powers for cancellation of bail only in terms of Section 437(5) of 1973 Code whereas the High Court and Sessions Court have been vested with powers under Section 439 of Cr.P.C., of 1973 to cancel “any bail granted under Chapter XXXIII of 1973 Code”. 12.1 Section 439(2) of Cr.P.C., 1973 deals with “any person who has been released on bail under this Chapter” i.e. Chapter XXXIII of 1973 Code, which engirths in itself, Section 438 of the Code (provision envisaging anticipatory bail/pre-arrest bail) as well. H realm of all kinds of bails, whether regular bail or anticipatory bail. Ergo, there is no conceptual difference between cancellation of regular bail and cancellation of anticipatory bail except that a Magistrate will not have statutory power to cancel an anticipatory bail granted by High Court or Sessions Court. 12.2. At this juncture, it would be profitable to consider an issue often springing up before Courts. Petition(s) labelled as plea(s) for “ of bail” are filed in Court(s), more often than not, whether such applicant is actually seeking “cancellation of bail” the grant of bail or on account of any supervening developments disentitling such accused to remain on bail OR where ought not to have been granted at all vide the impugned order, in the factual conspectus of such case. The 1973 Code neither stipulates the words “cancellation of bail” nor “setting-aside of a bail order” the words “any person who has been released on bail be arrested and committed to custody”. There is no gainsaying that there is a foundational difference between “cancellation of bail” order”; a difference which, by way of between chalk and cheese. The Hon 5 vested under this Chapter. In other words; the High Court is well empowered to cancel a bail granted by itself or by a Sessions Court or by the Court of a Magistrate while the Sessions Court is empowered to cancel a bail granted by High Court or by itself or by a Magistrate. However, a Sessions Court can cancel bail granted by High Court only on account of supervening/new circumstances or on account of misconduct of such accused y condition(s) imposed by the High Court while granting bail. The Magistrate can, of course, cancel bail granted by him but he cannot cancel a bail granted by High Court or Sessions Court except when such accused has violated/contravened any condition(s) imposed upon by such High Court or Sessions Court while granting bail to such accused. This position, is indubitable, as a Magistrate has been vested with powers for cancellation of bail only in terms of Section 437(5) of 1973 and Sessions Court have been vested with powers under Section 439 of Cr.P.C., of 1973 to cancel “any bail granted under Chapter XXXIII of 1973 Code”. Section 439(2) of Cr.P.C., 1973 deals with “any person who has been released on bail under this Chapter” i.e. Chapter XXXIII of 1973 Code, which engirths in itself, Section 438 of the Code (provision envisaging arrest bail) as well. Hence such power operates in realm of all kinds of bails, whether regular bail or anticipatory bail. Ergo, there is no conceptual difference between cancellation of regular bail and cancellation of anticipatory bail except that a Magistrate will not have tatutory power to cancel an anticipatory bail granted by High Court or At this juncture, it would be profitable to consider an issue often springing up before Courts. Petition(s) labelled as plea(s) for “cancellation led in Court(s), more often than not, whether such applicant is cancellation of bail” on account of the accused misusing the grant of bail or on account of any supervening developments disentitling such accused to remain on bail OR where the plea raised is that, the bail ought not to have been granted at all vide the impugned order, in the factual conspectus of such case. The 1973 Code neither stipulates the words aside of a bail order” but only stipulat any person who has been released on bail be arrested and . There is no gainsaying that there is a foundational cancellation of bail” and “setting-aside of a bail ; a difference which, by way of simile, can be said to be as stark as he Hon’ble Supreme Court in cases of Ranjit vested under this Chapter. In other words; the High Court is well empowered to cancel a bail granted by itself or by a Sessions Court or by the cel a bail granted by High Court or by itself or by a Magistrate. However, a Sessions Court can cancel bail granted by High Court only on account of supervening/new circumstances or on account of misconduct of such accused y condition(s) imposed by the High Court while granting bail. The Magistrate can, of course, cancel bail granted by him but he cannot cancel a bail granted by High Court or Sessions Court any condition(s) imposed upon by such High Court or Sessions Court while granting bail to such accused. This position, is indubitable, as a Magistrate has been vested with powers for cancellation of bail only in terms of Section 437(5) of 1973 and Sessions Court have been vested with powers under Section 439 of Cr.P.C., of 1973 to cancel “any bail granted Section 439(2) of Cr.P.C., 1973 deals with “any person who has been released on bail under this Chapter” i.e. Chapter XXXIII of 1973 Code, which engirths in itself, Section 438 of the Code (provision envisaging ence such power operates in realm of all kinds of bails, whether regular bail or anticipatory bail. Ergo, there is no conceptual difference between cancellation of regular bail and cancellation of anticipatory bail except that a Magistrate will not have tatutory power to cancel an anticipatory bail granted by High Court or At this juncture, it would be profitable to consider an issue often cancellation led in Court(s), more often than not, whether such applicant is on account of the accused misusing the grant of bail or on account of any supervening developments disentitling the plea raised is that, the bail ought not to have been granted at all vide the impugned order, in the factual conspectus of such case. The 1973 Code neither stipulates the words but only stipulates any person who has been released on bail be arrested and . There is no gainsaying that there is a foundational aside of a bail , can be said to be as stark as Ranjit AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- -9898-2026 Singh (supra) and Neeru Yadav (supra) has incontestably articulated that “cancellation of bail” is sought for on account of supervening circumstances/subsequent developments/misconduct of accused etc. whereas “setting-aside of a bail order” is sought for by laying challenge to the said bail order on ground of it being perverse or based on irrelevant material(s). The parameters for consideration of t contrastive. 13. The next aspect that craves attention is as to what are the factors relevant for considering of a plea for “ of a bail order.”At the very outset; it deserves well settled a principle to be ratiocinated upon, that consideration(s) for grant of bail vis.-a-vis. cancellation/setting different. 14. In a plea seeking “cancellation of bail” show, primarily, subsequent supervening circumstances such as accused having endeavored to influence/intimidate witness(s) or accused having violated bail condition(s) or accused having committed another offence(s) or accused having secured bail by misrepresenting/concealing material fact(s) or bail having been granted in ignorance/violation of statutory provisions and factors of akin nature. The Hon’ble Supreme Court in the case of Himanshu Sharma (supra) has delineated the nature and kind of such factors as have been stated by this Court hereinabove. 14.1. Further, the Hon’ble Supreme Court in the case of (supra) has enounced regarding the nature and degree of burden upon the applicant (seeking cancellation of bail). The plea of such an applicant has to be tested on the anvil of preponderance of is not required to prove, beyond reasonable doubt, the facts pleaded by him in support of such a plea. 15. In a plea seeking “setting required to be considered are as to whether bail has been granted on relevant consideration(s); grounds required have been duly factored into the order granting bail and other factors of nature. The Hon’ble Supreme Court in the case of held that the High Court or Sessions Court can set bail passed by an inferior Court if such order is based on irrelevant considerations, order granting bail has resulted in miscarriage of justice etc. It goes without saying that the High Court or Sessions Court; while dealing a plea for setting-aside a bail order; sits in a jurisdiction, which is akin to appellate jurisdiction & hence it can look into the veracity and propriety of 6 (supra) has incontestably articulated that is sought for on account of supervening ces/subsequent developments/misconduct of accused etc. whereas is sought for by laying challenge to the said bail order on ground of it being perverse or based on irrelevant material(s). The parameters for consideration of the two are, accordingly, different and The next aspect that craves attention is as to what are the factors relevant for considering of a plea for “cancellation of bail” or “setting-aside At the very outset; it deserves to be noted that, it is too far a principle to be ratiocinated upon, that consideration(s) for cancellation/setting-aside thereof are entirely cancellation of bail”; such applicant ought to show, primarily, subsequent supervening circumstances such as accused having endeavored to influence/intimidate witness(s) or accused having violated bail condition(s) or accused having committed another offence(s) or y misrepresenting/concealing material fact(s) or bail having been granted in ignorance/violation of statutory provisions and factors of akin nature. The Hon’ble Supreme Court in the case of (supra) has delineated the nature and kind of such factors as have been stated by this Court hereinabove. Further, the Hon’ble Supreme Court in the case of Sanjay Gandhi (supra) has enounced regarding the nature and degree of burden upon the applicant (seeking cancellation of bail). The plea of such an applicant has to be tested on the anvil of preponderance of probabilities & such an applicant yond reasonable doubt, the facts pleaded by him setting-aside of a bail order”; the factors required to be considered are as to whether bail has been granted on relevant consideration(s); grounds required to be evaluated for grant of bail have been duly factored into the order granting bail and other factors of akin nature. The Hon’ble Supreme Court in the case of Jagjit Singh (supra) has held that the High Court or Sessions Court can set-aside an order granting bail passed by an inferior Court if such order is based on irrelevant considerations, order granting bail has resulted in miscarriage of justice etc. It goes without saying that the High Court or Sessions Court; while dealing a e a bail order; sits in a jurisdiction, which is akin to appellate jurisdiction & hence it can look into the veracity and propriety of (supra) has incontestably articulated that is sought for on account of supervening ces/subsequent developments/misconduct of accused etc. whereas is sought for by laying challenge to the said bail order on ground of it being perverse or based on irrelevant material(s). he two are, accordingly, different and The next aspect that craves attention is as to what are the factors aside to be noted that, it is too far a principle to be ratiocinated upon, that consideration(s) for aside thereof are entirely ought to show, primarily, subsequent supervening circumstances such as accused having endeavored to influence/intimidate witness(s) or accused having violated bail condition(s) or accused having committed another offence(s) or y misrepresenting/concealing material fact(s) or bail having been granted in ignorance/violation of statutory provisions and factors of akin nature. The Hon’ble Supreme Court in the case of (supra) has delineated the nature and kind of such Sanjay Gandhi (supra) has enounced regarding the nature and degree of burden upon the applicant (seeking cancellation of bail). The plea of such an applicant has to & such an applicant yond reasonable doubt, the facts pleaded by him ; the factors required to be considered are as to whether bail has been granted on to be evaluated for grant of bail akin (supra) has anting bail passed by an inferior Court if such order is based on irrelevant considerations, order granting bail has resulted in miscarriage of justice etc. It goes without saying that the High Court or Sessions Court; while dealing a e a bail order; sits in a jurisdiction, which is akin to appellate jurisdiction & hence it can look into the veracity and propriety of AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- -9898-2026 the order (granting bail) from all the dealing with such a plea, ought not to substi expressed in the impugned order. 16. It would not be pragmatic to even attempt to lay parameters in this regard as every case, especially a criminal case, is sui generis. Such a quixotic attempt ought to formulae can be laid down in this regard. 17. As an epilogue to above discussion, the following principles emerge: I. (i) There is a conceptual distinction, between “setting-aside of a bail order”. In the factors required to be considered are circumstances/events or mis-conduct of accused seeking“setting-aside of a bail order”; considered are akin to the order in question being unjustified or illegal or not based on relevant consideration(s). In other words, a plea seeking “setting aside of a bail order” is more in the nature of laying challenge to an order granting bail before a superior Court upon me (ii) It would be pragmatic as also desirable, for the cause of ease and clarity, that a plea filed under Section 439 of Cr.P.C., 1973 clearly states as to whether the plea is for “cancellation of bail” or for “setting aside of a bail order.” or on both accounts. xxx xxx xxx xxx IV. Plea seeking cancellation of anticipatory bail/pre (i) A High Court has power to cancel an anticipatory bail gra it or by a Sessions Court. (ii) A Sessions Court has power to cancel an anticipatory bail granted by High Court or earlier granted by it. cancel anticipatory bail granted by High Court only where the accused has violated any condition(s) imposed by the High Court (while granting such bail) or on account of such accused having misused liberty granted to him by trying to influence witness(s) or having tried to delay trial by absenting himself or having committed another of factors of akin nature. In other words, a Sessions Court can cancel anticipatory bail granted to an accused by High Court only on account of such likes supervening/subsequent events but cannot adjudicate upon veracity of the High Court order (whereby such bail was granted to such accused.) 7 the order (granting bail) from all the perspectives. However, a Court while dealing with such a plea, ought not to substitute its own opinion with the one It would not be pragmatic to even attempt to lay-down exhaustive parameters in this regard as every case, especially a criminal case, is sui generis. Such a quixotic attempt ought to be avoided as no inexorable formulae can be laid down in this regard. As an epilogue to above discussion, the following principles (i) There is a conceptual distinction, between “cancellation of bail” . In a plea seeking “cancellation of bail” the factors required to be considered are akin to supervening conduct of accused whereas in a plea aside of a bail order”; the factors required to be the order in question being unjustified or illegal or not based on relevant consideration(s). In other words, a plea seeking “setting aside of a bail order” is more in the nature of laying challenge to an order granting bail before a superior Court upon merits thereof. It would be pragmatic as also desirable, for the cause of ease and clarity, that a plea filed under Section 439 of Cr.P.C., 1973 clearly states as “cancellation of bail” or for “setting aside of a xxx xxx xxx xxx Plea seeking cancellation of anticipatory bail/pre-arrest order A High Court has power to cancel an anticipatory bail granted by A Sessions Court has power to cancel an anticipatory bail granted by High Court or earlier granted by it. However, the Sessions Court can cancel anticipatory bail granted by High Court only where the accused has d any condition(s) imposed by the High Court (while granting such bail) or on account of such accused having misused liberty granted to him by trying to influence witness(s) or having tried to delay trial by absenting himself or having committed another offence(s) while on bail and other factors of akin nature. In other words, a Sessions Court can cancel anticipatory bail granted to an accused by High Court only on account of such likes supervening/subsequent events but cannot adjudicate upon he High Court order (whereby such bail was granted to such . However, a Court while tute its own opinion with the one down exhaustive parameters in this regard as every case, especially a criminal case, is sui be avoided as no inexorable As an epilogue to above discussion, the following principles ”& cancellation of bail”; to supervening in a plea the factors required to be the order in question being unjustified or illegal or not based on relevant consideration(s). In other words, a plea seeking “setting aside of a bail order” is more in the nature of laying challenge to an It would be pragmatic as also desirable, for the cause of ease and clarity, that a plea filed under Section 439 of Cr.P.C., 1973 clearly states as “cancellation of bail” or for “setting aside of a nted by A Sessions Court has power to cancel an anticipatory bail granted However, the Sessions Court can cancel anticipatory bail granted by High Court only where the accused has d any condition(s) imposed by the High Court (while granting such bail) or on account of such accused having misused liberty granted to him by trying to influence witness(s) or having tried to delay trial by absenting fence(s) while on bail and other factors of akin nature. In other words, a Sessions Court can cancel anticipatory bail granted to an accused by High Court only on account of such likes supervening/subsequent events but cannot adjudicate upon he High Court order (whereby such bail was granted to such AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- -9898-2026 (iii) In case cancellation of an anticipatory bail granted by Sessions Court is sought for; such plea ought to be filed ordinarily before Sessions Court itself. However, since there is concurr Court as also Sessions Court in terms of Section 439(2) of Cr.P.C. of 1973, the filing of such a plea straight away before the High Court is not barred. At the same time, it would be expedient that such a plea (straight away f before High Court) must show cogent reasons for not approaching the Sessions Court in first instance. (iv) The factors for consideration in a plea for cancellation of an anticipatory bail are whether the accused has misused liberty granted to him by trying to influence witness(s) or has tried to delay trial or has committed another offence(s) while on bail, whether accused has flouted the cancellation of bail, whether bail was procured by misrepresentation or fraud or concealing relevant material, and simi There is no gainsaying that above factors are only illustrative in nature as it is not axiomatic to exhaustively enumerate them. (v) Where such plea raises ground(s) that bail has been granted on account of misrepresentation of facts or a fraud having been played on Court which has granted bail or concealment of material/relevant facts; it would be expedient that such plea be filed, in the first instance itself, before the Court which had granted bail in question. (vi) The degree and nature of proof required to be shown by an applicant (seeking cancellation of an anticipatory bail) is that of preponderance of probabilities and not one of being beyond reasonable doubt. V. Plea seeking setting aside of an anticipatory bail/pre (i) A plea seeking setting aside of an anticipatory bail/pre order by a Sessions Court has to be essentially filed before High Court. (ii) The factor, required to be considered in a plea seeking setting aside of an anticipatory/pre-arrest bail order; is as to whether the impugned order (granting anticipatory bail/pre nature and gravity of allegations ag crime(s) alleged, need for custodial interrogation, likelihood of accused influencing the investigation/witnesses, likelihood of the accused absconding from process of justice etc. VI. Where a plea made under Sectio raises grounds regarding “cancellation of bail” as also for “setting aside of bail order”, such plea has to be essentially made before the superior Court. 8 In case cancellation of an anticipatory bail granted by Sessions Court is sought for; such plea ought to be filed ordinarily before Sessions Court itself. However, since there is concurrent jurisdiction of the High Court as also Sessions Court in terms of Section 439(2) of Cr.P.C. of 1973, the filing of such a plea straight away before the High Court is not barred. At the same time, it would be expedient that such a plea (straight away filed before High Court) must show cogent reasons for not approaching the The factors for consideration in a plea for cancellation of an anticipatory bail are whether the accused has misused liberty granted to him g to influence witness(s) or has tried to delay trial or has committed another offence(s) while on bail, whether accused has flouted the cancellation of bail, whether bail was procured by misrepresentation or fraud or concealing relevant material, and similar factors of akin nature. There is no gainsaying that above factors are only illustrative in nature as it is not axiomatic to exhaustively enumerate them. Where such plea raises ground(s) that bail has been granted on facts or a fraud having been played on Court which has granted bail or concealment of material/relevant facts; it would be expedient that such plea be filed, in the first instance itself, before the Court nature of proof required to be shown by an applicant (seeking cancellation of an anticipatory bail) is that of preponderance of probabilities and not one of being beyond reasonable Plea seeking setting aside of an anticipatory bail/pre-arrest bail order A plea seeking setting aside of an anticipatory bail/pre-arrest bail order by a Sessions Court has to be essentially filed before High Court. The factor, required to be considered in a plea seeking setting arrest bail order; is as to whether the impugned order (granting anticipatory bail/pre-arrest bail) has objectively dealt with nature and gravity of allegations against accused, role of accused in the crime(s) alleged, need for custodial interrogation, likelihood of accused influencing the investigation/witnesses, likelihood of the accused absconding Where a plea made under Section 439(2) of Cr.P.C. 1973 raises grounds regarding “cancellation of bail” as also for “setting aside of bail order”, such plea has to be essentially made before the superior Court. In case cancellation of an anticipatory bail granted by Sessions Court is sought for; such plea ought to be filed ordinarily before Sessions ent jurisdiction of the High Court as also Sessions Court in terms of Section 439(2) of Cr.P.C. of 1973, the filing of such a plea straight away before the High Court is not barred. At the same time, it would be expedient that such a plea (straight away filed before High Court) must show cogent reasons for not approaching the The factors for consideration in a plea for cancellation of an anticipatory bail are whether the accused has misused liberty granted to him g to influence witness(s) or has tried to delay trial or has committed another offence(s) while on bail, whether accused has flouted the cancellation of bail, whether bail was procured by misrepresentation or lar factors of akin nature. There is no gainsaying that above factors are only illustrative in nature as it Where such plea raises ground(s) that bail has been granted on facts or a fraud having been played on Court which has granted bail or concealment of material/relevant facts; it would be expedient that such plea be filed, in the first instance itself, before the Court nature of proof required to be shown by an applicant (seeking cancellation of an anticipatory bail) is that of preponderance of probabilities and not one of being beyond reasonable arrest bail The factor, required to be considered in a plea seeking setting arrest bail order; is as to whether the impugned arrest bail) has objectively dealt with ainst accused, role of accused in the crime(s) alleged, need for custodial interrogation, likelihood of accused influencing the investigation/witnesses, likelihood of the accused absconding n 439(2) of Cr.P.C. 1973 raises grounds regarding “cancellation of bail” as also for “setting aside of bail order”, such plea has to be essentially made before the superior Court. AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- 8. raised by le has been filed for cancellation of the anticipatory bail granted to the respondent No.2 vide order dated Additional petitioner has not brought on record any material to demonstrate that after the grant of anticipatory bail, the witnesses, tamper with evidence, evade investigation or violate any condition imp petitioner are largely speculative and not supported by The principal contention raised on behalf of the petitioner is that while granting anticipatory bail, the learned Court below the gravity of the allegations, the criminal antecedents of respondent No.2, the requirement of custodial interrogation and the necessity of recovery of the alleged cheated amount. It has further been contended that respondent No.2 has misused the concession of bail by threatening the complainant and, therefore, the order granting anticipatory bail deserves to be set aside. scope of consideration in a petition seeking cancellation of is altogether different fr for grant of bail. The material placed before this Court does not persuade this Court to hold that the impugned order suffers from or illegality cancellation of bail. Although the petitioner has alleged that respondent No.2 has criminal antecedents and has extended threats after grant of anticipatory bail -9898-2026 The averments made in the petition as also the arguments raised by learned counsel for the petitioner, indubitably, show that petition has been filed for cancellation of the anticipatory bail granted to the respondent No.2 vide order dated 31.01.2026 Additional Sessions Judge, Fatehgarh Sahib petitioner has not brought on record any material to demonstrate that after the grant of anticipatory bail, respondent No.2 has attempted to influence witnesses, tamper with evidence, evade investigation or violate any condition imposed by the Court. The apprehensions expressed by the petitioner are largely speculative and not supported by The principal contention raised on behalf of the petitioner is that while granting anticipatory bail, the learned Court below the gravity of the allegations, the criminal antecedents of respondent No.2, the requirement of custodial interrogation and the necessity of recovery of the alleged cheated amount. It has further been contended that respondent 2 has misused the concession of bail by threatening the complainant and, therefore, the order granting anticipatory bail deserves to be set aside. scope of consideration in a petition seeking cancellation of is altogether different from that applicable while considering an application for grant of bail. The material placed before this Court does not persuade this Court to hold that the impugned order suffers from or illegality which would justify interference in e cancellation of bail. Although the petitioner has alleged that respondent No.2 has criminal antecedents and has extended threats after grant of anticipatory bail but no material has been placed before this Court to 9 The averments made in the petition as also the arguments arned counsel for the petitioner, indubitably, show that petition has been filed for cancellation of the anticipatory bail granted to the 31.01.2026 (Annexure P-2) passed by Fatehgarh Sahib. In the present case, the petitioner has not brought on record any material to demonstrate that after espondent No.2 has attempted to influence witnesses, tamper with evidence, evade investigation or violate any osed by the Court. The apprehensions expressed by the petitioner are largely speculative and not supported by any cogent material. The principal contention raised on behalf of the petitioner is that while granting anticipatory bail, the learned Court below has failed to appreciate the gravity of the allegations, the criminal antecedents of respondent No.2, the requirement of custodial interrogation and the necessity of recovery of the alleged cheated amount. It has further been contended that respondent 2 has misused the concession of bail by threatening the complainant and, therefore, the order granting anticipatory bail deserves to be set aside. T scope of consideration in a petition seeking cancellation of anticipatory bail om that applicable while considering an application for grant of bail. The material placed before this Court does not persuade this Court to hold that the impugned order suffers from any patent perversity would justify interference in exercise of jurisdiction for cancellation of bail. Although the petitioner has alleged that respondent No.2 has criminal antecedents and has extended threats after grant of no material has been placed before this Court to The averments made in the petition as also the arguments arned counsel for the petitioner, indubitably, show that petition has been filed for cancellation of the anticipatory bail granted to the ) passed by e present case, the petitioner has not brought on record any material to demonstrate that after espondent No.2 has attempted to influence witnesses, tamper with evidence, evade investigation or violate any osed by the Court. The apprehensions expressed by the material. The principal contention raised on behalf of the petitioner is that while failed to appreciate the gravity of the allegations, the criminal antecedents of respondent No.2, the requirement of custodial interrogation and the necessity of recovery of the alleged cheated amount. It has further been contended that respondent 2 has misused the concession of bail by threatening the complainant and, The bail om that applicable while considering an application for grant of bail. The material placed before this Court does not persuade patent perversity xercise of jurisdiction for cancellation of bail. Although the petitioner has alleged that respondent No.2 has criminal antecedents and has extended threats after grant of no material has been placed before this Court to AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- substantiate imposed while granting anticipatory bail or he has failed to join investigation as directed by the learned Court below. There is also no material showing that respondent No.2 has attempted to abscon interfered with the investigation or has committed any overt act which would make it impossible for a fair investigation or trial to proceed. allegations regarding intimidation and influence over witnesses are serious in nature. However, bald a material cancellation of 9. not required to conclusively determine culpability or examination of evidence. investigation, appropriate remedies are available under law; however, such grievances ca granted. It is worthwhile to note herein that investigation pursuant to the prosecution has not sought cancellation of bail on conceded position before this Court that the FIR was registered on 21.01.2026 cooperation or attempt by respondent No.2 to interfere with the investigation. It is trite law that the cancellation of bail are distinct. Cancellation of bail already granted requires demonstration of supervening circumstances such as misuse of liberty, tampering with evidence, intimidation of witnesses or delibera -9898-2026 substantiate that respondent No.2 has violated any of the condition imposed while granting anticipatory bail or he has failed to join investigation as directed by the learned Court below. There is also no material showing that respondent No.2 has attempted to abscon interfered with the investigation or has committed any overt act which would make it impossible for a fair investigation or trial to proceed. allegations regarding intimidation and influence over witnesses are serious in nature. However, bald allegations unsupported by evidence cannot, by itself, constitute sufficient grounds for cancellation of anticipatory bail. At the stage of consideration of anticipatory not required to conclusively determine culpability or examination of evidence. If the petitioner is aggrieved by the manner of investigation, appropriate remedies are available under law; however, such grievances cannot automatically result in cancellation of bail already It is worthwhile to note herein that investigation pursuant to the grant of anticipatory prosecution has not sought cancellation of bail on conceded position before this Court that the FIR was registered on 21.01.2026 and the investigating agency has not reported any non cooperation or attempt by respondent No.2 to interfere with the investigation. It is trite law that the consideration(s) for grant of bail and for cancellation of bail are distinct. Cancellation of bail already granted requires demonstration of supervening circumstances such as misuse of liberty, tampering with evidence, intimidation of witnesses or delibera 10 that respondent No.2 has violated any of the condition imposed while granting anticipatory bail or he has failed to join investigation as directed by the learned Court below. There is also no material showing that respondent No.2 has attempted to abscond, has interfered with the investigation or has committed any overt act which would make it impossible for a fair investigation or trial to proceed. The allegations regarding intimidation and influence over witnesses are serious llegations unsupported by any independent constitute sufficient grounds for consideration of anticipatory bail, the Court is not required to conclusively determine culpability or to conduct a detailed If the petitioner is aggrieved by the manner of investigation, appropriate remedies are available under law; however, such nnot automatically result in cancellation of bail already It is worthwhile to note herein that respondent No.2 has joined grant of anticipatory bail and that the prosecution has not sought cancellation of bail on this ground. It is conceded position before this Court that the FIR was registered on and the investigating agency has not reported any non cooperation or attempt by respondent No.2 to interfere with the consideration(s) for grant of bail and for cancellation of bail are distinct. Cancellation of bail already granted requires demonstration of supervening circumstances such as misuse of liberty, tampering with evidence, intimidation of witnesses or deliberate evasion of that respondent No.2 has violated any of the condition(s) imposed while granting anticipatory bail or he has failed to join investigation as directed by the learned Court below. There is also no d, has interfered with the investigation or has committed any overt act which The allegations regarding intimidation and influence over witnesses are serious independent constitute sufficient grounds for bail, the Court is conduct a detailed If the petitioner is aggrieved by the manner of investigation, appropriate remedies are available under law; however, such nnot automatically result in cancellation of bail already the bail and that the It is conceded position before this Court that the FIR was registered on and the investigating agency has not reported any non- cooperation or attempt by respondent No.2 to interfere with the consideration(s) for grant of bail and for cancellation of bail are distinct. Cancellation of bail already granted requires demonstration of supervening circumstances such as misuse of liberty, te evasion of AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- the judicial process. Mere dissatisfaction with the reasoning of the Court below which has granted the bail or the seriousness of the offence, by itself, is not sufficient to recall such an order. Learned counsel has laid much emphasis that t nature, which according to the petitioner, ought to have been considered by the Court below at the time of grant of anticipatory bail. In the considered opinion of this Court, the petitioner has no supervening material before this Court. A mere allegation of seriousness of offence without concrete material cannot justify the cancellation of bail. Moreover, such a plea cannot, by itself, render the order granting the bail perverse. The order passed by the Sahib is a well from vice of non the entirety of the facts and circumsta find any good ground to hold that the Sessions Court, while passing the impugned order, has overstepped its jurisdiction or has not exercised the same in right perspective. Therefore, the petition(s) in hand deserves rejection. 10. the case in hand, no ground is made out to set earlier granted to respondent No.2 vide the impugned order. Therefore, the petition in hand deserve 11. under Section 483(3) of the BNSS, 2023, seeking cancellation of -9898-2026 the judicial process. Mere dissatisfaction with the reasoning of the Court below which has granted the bail or the seriousness of the offence, by itself, is not sufficient to recall such an order. Learned counsel has laid much emphasis that the allegations against the respondent No.2 are serious , which according to the petitioner, ought to have been considered by the Court below at the time of grant of anticipatory bail. In the considered opinion of this Court, the petitioner has no supervening material before this Court. A mere allegation of seriousness of offence without concrete material cannot justify the cancellation of bail. Moreover, such a plea cannot, by itself, render the order granting the bail rse. The order passed by the Additional is a well-reasoned speaking order and cannot be said to be suffering from vice of non-application of judicial mind. This Court, keeping in view the entirety of the facts and circumstances of the case(s) in hand, does not find any good ground to hold that the Sessions Court, while passing the impugned order, has overstepped its jurisdiction or has not exercised the same in right perspective. Therefore, the petition(s) in hand deserves rejection. Keeping in view the entirety of the facts and circumstances of the case in hand, no ground is made out to set earlier granted to respondent No.2 vide the impugned order. Therefore, the petition in hand deserves rejection. As a sequel to the above discussion, the present petition filed under Section 483(3) of the BNSS, 2023, seeking cancellation of 11 the judicial process. Mere dissatisfaction with the reasoning of the Court below which has granted the bail or the seriousness of the offence, by itself, is not sufficient to recall such an order. Learned counsel has laid much he allegations against the respondent No.2 are serious , which according to the petitioner, ought to have been considered by the Court below at the time of grant of anticipatory bail. In the considered opinion of this Court, the petitioner has not brought any fresh or supervening material before this Court. A mere allegation of seriousness of offence without concrete material cannot justify the cancellation of bail. Moreover, such a plea cannot, by itself, render the order granting the bail Additional Sessions Judge, Fatehgarh reasoned speaking order and cannot be said to be suffering application of judicial mind. This Court, keeping in view nces of the case(s) in hand, does not find any good ground to hold that the Sessions Court, while passing the impugned order, has overstepped its jurisdiction or has not exercised the same in right perspective. Therefore, the petition(s) in hand deserves Keeping in view the entirety of the facts and circumstances of the case in hand, no ground is made out to set-aside the anticipatory bail earlier granted to respondent No.2 vide the impugned order. Therefore, the As a sequel to the above discussion, the present petition filed under Section 483(3) of the BNSS, 2023, seeking cancellation of the judicial process. Mere dissatisfaction with the reasoning of the Court below which has granted the bail or the seriousness of the offence, by itself, is not sufficient to recall such an order. Learned counsel has laid much in , which according to the petitioner, ought to have been considered by the Court below at the time of grant of anticipatory bail. In the considered t brought any fresh or supervening material before this Court. A mere allegation of seriousness of offence without concrete material cannot justify the cancellation of bail. Moreover, such a plea cannot, by itself, render the order granting the bail Judge, Fatehgarh reasoned speaking order and cannot be said to be suffering application of judicial mind. This Court, keeping in view nces of the case(s) in hand, does not find any good ground to hold that the Sessions Court, while passing the impugned order, has overstepped its jurisdiction or has not exercised the same in right perspective. Therefore, the petition(s) in hand deserves Keeping in view the entirety of the facts and circumstances of aside the anticipatory bail earlier granted to respondent No.2 vide the impugned order. Therefore, the As a sequel to the above discussion, the present petition filed under Section 483(3) of the BNSS, 2023, seeking cancellation of AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document CRM-M- anticipatory bail order dated Additional 12. hereinabove shall be construed as an expression of opinion on the merits of the case. 13. July 28, 202 Ajay -9898-2026 anticipatory bail order dated 31.01.2026 Additional Sessions Judge, Fatehgarh Sahib It, indubitably, goes without saying that nothing said hereinabove shall be construed as an expression of opinion on the merits of Pending application(s), if any, shall also stand disposed off. 2026 Whether speaking/reasoned: Whether reportable: 12 (Annexure P-2) passed by learned rh Sahib is dismissed. It, indubitably, goes without saying that nothing said hereinabove shall be construed as an expression of opinion on the merits of Pending application(s), if any, shall also stand disposed off. (SUMEET GOEL) JUDGE Yes/No Yes/No ) passed by learned It, indubitably, goes without saying that nothing said hereinabove shall be construed as an expression of opinion on the merits of AJAY KUMAR 2026.07.29 14:01 I attest to the accuracy and integrity of this document