CRM-M- IN THE HIGH COURT OF PUNJAB AND HARYANA AT 101 Priyanshu Sharma alias Prince State of Haryana and another Date of decision: Date of Uploading : 0 CORAM: Present: SUMEET GOEL 1. the Bharatiya Nagarik Suraksha Sanhita, 2023 ‘the BNSS’) FIR No. 43 dated 22.04.2026 registered under Sections 120 506 of IPC arrest/anticipatory bail before this Court which was dismissed as withdrawn on 15.05.2026 2. present petition is a second attempt by the petitioner for grant of anticipatory bail. A second anticipatory under law; however, it requires demonstration of a substantial change in -33165-2026 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Priyanshu Sharma alias Prince V/s State of Haryana and another Date of decision: 03.09.2026 Date of Uploading : 07.09.2026 CORAM: HON’BLE MR. JUSTICE SUMEET GOEL Mr. Kanwar Abhay Singh, Advocate for the petitioner. Mr. Gurmeet Singh, AAG Haryana. Mr. Navjit Singh, Advocate for respondent No.2 ***** SUMEET GOEL, J. (Oral) The present petition is the second attempt under the Bharatiya Nagarik Suraksha Sanhita, 2023 ‘the BNSS’) for grant of pre-arrest/anticipatory FIR No. 43 dated 22.04.2026 registered under Sections 120 IPC at Police Station Naggal, District Ambala. The petitioner had earlier applied for grant of pre arrest/anticipatory bail before this Court which was dismissed as withdrawn 15.05.2026. The relevant part of said order “2. Learned counsel appearing for the petitioner, after arguing some time, seeks to withdraw the petition in hand. 3. Ordered accordingly.” At the outset, it deserves to be mentioned herein that the present petition is a second attempt by the petitioner for grant of anticipatory bail. A second anticipatory bail petition is indeed maintainable under law; however, it requires demonstration of a substantial change in 1 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CRM-M-33165-2026 ....Petitioner ....Respondents HON’BLE MR. JUSTICE SUMEET GOEL Mr. Kanwar Abhay Singh, Advocate for the petitioner. Mr. Gurmeet Singh, AAG Haryana. Mr. Navjit Singh, Advocate for respondent No.2 he second attempt under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter to be referred as arrest/anticipatory bail to the petitioner in case FIR No. 43 dated 22.04.2026 registered under Sections 120-B, 406, 420 and at Police Station Naggal, District Ambala. The petitioner had earlier applied for grant of pre arrest/anticipatory bail before this Court which was dismissed as withdrawn . The relevant part of said order reads as under:- Learned counsel appearing for the petitioner, after arguing some time, seeks to withdraw the petition in hand. At the outset, it deserves to be mentioned herein that the present petition is a second attempt by the petitioner for grant of bail petition is indeed maintainable under law; however, it requires demonstration of a substantial change in Section 482 of (hereinafter to be referred as case B, 406, 420 and The petitioner had earlier applied for grant of pre- arrest/anticipatory bail before this Court which was dismissed as withdrawn for At the outset, it deserves to be mentioned herein that the present petition is a second attempt by the petitioner for grant of bail petition is indeed maintainable under law; however, it requires demonstration of a substantial change in AJAY KUMAR 2026.09.05 12:41 I attest to the accuracy and integrity of this document CRM-M- circumstances since the proposition of law that such change must be significant and not merely superficial or technical, to warrant reconsideration. This standard ensures that the remedy of successive bail petitions is not misused through repeated filings but is available only when new and material factors arise that alter the initial assessment of be made to the judgment passed by this Court titled as State of Haryana, 2024(3) RCR(Criminal) 65 under:- -33165-2026 circumstances since the dismissal of the proposition of law that such change must be significant and not merely superficial or technical, to warrant reconsideration. This standard ensures that the remedy of successive bail petitions is not misused through repeated filings but is available only when new and material factors arise that alter the initial assessment of the case. A profitable reference in this regard can be made to the judgment passed by this Court titled as State of Haryana, 2024(3) RCR(Criminal) 65 “11. As an epilogue to the above rumination, the f principles emerge: I Second/successive anticipatory bail petition(s) filed under Section 438 of Cr.P.C., 1973 is maintainable in law & hence such petition ought not to be rejected solely on the ground of maintainability thereof. II Such second/successive anticipatory bail petition(s) is maintainable whether earlier petition was dismissed as withdrawn/dismissed as not pressed/dismissed for non or earlier petition was dismissed on merits. III For the second/successive anticipatory ba succeed, the petitioner/applicant shall be essentially/pertinently required to show substantial change in circumstances and showing of a mere superficial or ostensible change would not suffice. IV No exhaustive guidelines can possibly b what would constitute substantial change in circumstances as every case has its own unique facts/circumstance. Accordingly, this issue is best left to the judicial wisdom and discretion of the Court dealing with such second/successive ant petition(s). V In case a Court chooses to grant second/successive anticipatory bail petition(s), cogent and lucid reasons are pertinently required to be recorded for granting such plea despite such a plea being second/successive petition(s). In other words, 2 dismissal of the earlier petition. It is a settled proposition of law that such change must be significant and not merely superficial or technical, to warrant reconsideration. This standard ensures that the remedy of successive bail petitions is not misused through repeated filings but is available only when new and material factors arise that alter the case. A profitable reference in this regard can be made to the judgment passed by this Court titled as Bhisham Singh vs. State of Haryana, 2024(3) RCR(Criminal) 65, relevant whereof reads as As an epilogue to the above rumination, the following Second/successive anticipatory bail petition(s) filed under Section 438 of Cr.P.C., 1973 is maintainable in law & hence such petition ought not to be rejected solely on the ground of successive anticipatory bail petition(s) is maintainable whether earlier petition was dismissed as withdrawn/dismissed as not pressed/dismissed for non-prosecution or earlier petition was dismissed on merits. For the second/successive anticipatory bail petition(s) to succeed, the petitioner/applicant shall be essentially/pertinently required to show substantial change in circumstances and showing of a mere superficial or ostensible change would not No exhaustive guidelines can possibly be laid down as to what would constitute substantial change in circumstances as every case has its own unique facts/circumstance. Accordingly, this issue is best left to the judicial wisdom and discretion of the Court dealing with such second/successive anticipatory bail In case a Court chooses to grant second/successive anticipatory bail petition(s), cogent and lucid reasons are pertinently required to be recorded for granting such plea despite such a plea being second/successive petition(s). In other words, earlier petition. It is a settled proposition of law that such change must be significant and not merely superficial or technical, to warrant reconsideration. This standard ensures that the remedy of successive bail petitions is not misused through repeated filings but is available only when new and material factors arise that alter the case. A profitable reference in this regard can Bhisham Singh vs. relevant whereof reads as ollowing Second/successive anticipatory bail petition(s) filed under Section 438 of Cr.P.C., 1973 is maintainable in law & hence such petition ought not to be rejected solely on the ground of successive anticipatory bail petition(s) is maintainable whether earlier petition was dismissed as prosecution il petition(s) to succeed, the petitioner/applicant shall be essentially/pertinently required to show substantial change in circumstances and showing of a mere superficial or ostensible change would not e laid down as to what would constitute substantial change in circumstances as every case has its own unique facts/circumstance. Accordingly, this issue is best left to the judicial wisdom and discretion of the icipatory bail In case a Court chooses to grant second/successive anticipatory bail petition(s), cogent and lucid reasons are pertinently required to be recorded for granting such plea despite such a plea being second/successive petition(s). In other words, AJAY KUMAR 2026.09.05 12:41 I attest to the accuracy and integrity of this document CRM-M- as withdrawn on grant of anticipatory bail has been filed thereafter on substantial change in circumstance has been brought forward which would indicate that the petitioner is entitled to maintai grant of anticipatory bail. From the entire factual conspectus brought forward in the present petition, no fresh ground or circumstance is made out so as to enable the petitioner to file and maintain the second anticipatory bail petition. However, since the first anticipatory bail petition was dismissed as withdrawn and there was no adjudication on merits thereof, this Court deems it appropriate to decide the instant one on merits thereof well which has been adjudicated upon connected petition i.e. State of Haryana and another September 03, Ajay -33165-2026 the cause for a Court having successfully countenanced/entertained such second/successive petition(s) ought to be readily and clearly decipherable from the said order passed. VI Once a plea for anticipatory bail has been dismissed as withdrawn/dismissed as not presse or dismissed on merits by the High Court, no second/successive anticipatory bail petition(s) shall be entertained by a Sessions Court.” The first anticipatory bail filed by the petitioner was dismissed as withdrawn on 15.05.2026. The instant petition i.e. second petition for grant of anticipatory bail has been filed thereafter on substantial change in circumstance has been brought forward which would indicate that the petitioner is entitled to maintai grant of anticipatory bail. From the entire factual conspectus brought forward in the present petition, no fresh ground or circumstance is made out so as to enable the petitioner to file and maintain the second anticipatory etition. However, since the first anticipatory bail petition was dismissed as withdrawn and there was no adjudication on merits thereof, this Court deems it appropriate to decide the instant one on merits thereof which has been adjudicated upon and connected petition i.e. CRM-M-31351-2026 titled as State of Haryana and another of even date. September 03, 2026 Whether speaking/reasoned: Whether reportable: 3 r a Court having successfully countenanced/entertained such second/successive petition(s) ought to be readily and clearly decipherable from the said order Once a plea for anticipatory bail has been dismissed as withdrawn/dismissed as not pressed/dismissed for non-prosecution or dismissed on merits by the High Court, no second/successive anticipatory bail petition(s) shall be entertained by a Sessions The first anticipatory bail filed by the petitioner was dismissed . The instant petition i.e. second petition for grant of anticipatory bail has been filed thereafter on 05.06.2026. No fresh substantial change in circumstance has been brought forward which would indicate that the petitioner is entitled to maintain his second petition for grant of anticipatory bail. From the entire factual conspectus brought forward in the present petition, no fresh ground or circumstance is made out so as to enable the petitioner to file and maintain the second anticipatory etition. However, since the first anticipatory bail petition was dismissed as withdrawn and there was no adjudication on merits thereof, this Court deems it appropriate to decide the instant one on merits thereof and dismissed by this Court in 2026 titled as Karam Chand vs. of even date. (SUMEET GOEL) JUDGE Yes/No Yes/No r a Court having successfully countenanced/entertained such second/successive petition(s) ought to be readily and clearly decipherable from the said order Once a plea for anticipatory bail has been dismissed as prosecution or dismissed on merits by the High Court, no second/successive anticipatory bail petition(s) shall be entertained by a Sessions The first anticipatory bail filed by the petitioner was dismissed . The instant petition i.e. second petition for No fresh substantial change in circumstance has been brought forward which would n his second petition for grant of anticipatory bail. From the entire factual conspectus brought forward in the present petition, no fresh ground or circumstance is made out so as to enable the petitioner to file and maintain the second anticipatory etition. However, since the first anticipatory bail petition was dismissed as withdrawn and there was no adjudication on merits thereof, this Court deems it appropriate to decide the instant one on merits thereof as the Karam Chand vs. AJAY KUMAR 2026.09.05 12:41 I attest to the accuracy and integrity of this document