CRM-M-33850-2026 [1] IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH CRM-M-33850-2026 Date of decision: 15.06.2026 Bikramjeet Singh ...Pe%%oner Versus State of Punjab ...Respondent CORAM: HON'BLE MR. JUSTICE DEEPAK GUPTA Present: Mr. Sohrab Dhanda, Advocate for the pe%%oner. Mr. Ravneet Singh Joshi, DAG, Punjab. **** DEEPAK GUPTA, J. (ORAL) By way of this pe%%on filed under Sec%on 482 of the Bhara%ya Nagarik Suraksha Sanhita, 2023 (Sec%on 438 Cr.P.C), pe%%oner prays for grant of an%cipatory bail in case FIR No.51 dated 26.03.2026 registered under Sec%ons 85 and 115(2) of the Bhara%ya Nyaya Sanhita, 2023 at Police Sta%on Mullanpur, District S.A.S. Nagar (Mohali). 2. Learned counsel for the pe%%oner submits that the pe%%oner has been falsely implicated. It is argued that the allega%ons are exaggerated and arise out of matrimonial discord. Learned counsel further submits that the pe%%oner is ready and willing to join the inves%ga%on and that custodial interroga%on is not required. 3. I have heard learned counsel for the pe%%oner and have gone through the paper-book. 4. The FIR has been lodged by the wife of the pe%%oner alleging that a>er about two years of marriage, the pe%%oner and his family members started subjec%ng her to physical and mental cruelty on account of dowry demands. It is further alleged that she was turned out of the matrimonial home and, despite interven%on of the Panchayat and her subsequent return, the pe%%oner again YOGESH MEHTA 2026.06.15 17:06 I attest to the accuracy and integrity of this document CRM-M-33850-2026 [2] started demanding ₹5,00,000/- and subjected her to harassment. A specific allega%on has also been levelled regarding an occurrence dated 23.03.2026, when she was allegedly beaten by the pe%%oner, compelling her to seek medical treatment. This allega%on is supported by medical evidence. 5. At the stage of considera%on of an%cipatory bail, the Court is not required to conduct a me%culous examina%on of the evidence or record findings regarding the truthfulness of the allega%ons. The Court is only required to examine whether the accusa%ons disclose a prima facie case and whether custodial interroga%on is necessary in the facts and circumstances of the case. The parameters governing grant of an%cipatory bail have been authorita%vely laid down by the Hon'ble Supreme Court in Gurbaksh Singh Sibbia versus State of Punjab, (1980) 2 SCC 565 and Sushila Aggarwal versus State (NCT of Delhi), (2020) 5 SCC 1. 6. In the present case, the allega%ons are not vague or omnibus in nature. The pe%%oner is the husband of the complainant and specific allega%ons have been levelled against him regarding demand of money, acts of cruelty and physical assault. The allega%ons are further stated to be supported by the medical record pertaining to the injuries suffered by the complainant. At this stage, such material cannot be brushed aside as being inherently improbable. 7. There is yet another aspect of the maEer. The inves%ga%on is stated to be at a stage, where recovery of the complainant's istridhan remains to be effected. The Hon'ble Supreme Court has repeatedly held that where recovery of ar%cles is yet to be made and custodial interroga%on may facilitate a meaningful inves%ga%on, grant of an%cipatory bail may not be jus%fied. The extraordinary relief of an%cipatory bail is not intended to obstruct a fair inves%ga%on or render the inves%ga%ng agency powerless in securing recoveries relevant to the offence under inves%ga%on. 8. This Court also cannot lose sight of the nature of allega%ons involved. Offences rela%ng to cruelty and harassment of a married woman within YOGESH MEHTA 2026.06.15 17:06 I attest to the accuracy and integrity of this document CRM-M-33850-2026 [3] the matrimonial home are ordinarily commiEed within the privacy of the household and the evidence is largely within the knowledge of the persons concerned. Grant of pre-arrest bail at the threshold, when the inves%ga%on is s%ll in progress and recoveries are yet to be effected, may adversely impact the inves%ga%on. 9. Learned counsel for the pe%%oner has not been able to point out any circumstance indica%ng that the criminal proceedings are manifestly mala fide or that the allega%ons are so inherently improbable as to warrant the extraordinary protec%on of an%cipatory bail. Mere readiness to join inves%ga%on, by itself, cannot cons%tute a ground for grant of an%cipatory bail when the nature of accusa%ons and the requirements of inves%ga%on jus%fy custodial interroga%on. 10. Keeping in view the nature and gravity of allega%ons, the specific role aEributed to the pe%%oner, the requirement of recovery of istridhan and the stage of inves%ga%on, this Court does not find it to be a fit case for grant of an%cipatory bail. 11. Consequently, the present pe%%on is dismissed. 12. However, anything observed herein shall be construed only for the purpose of deciding the present pe%%on and shall not be treated as an expression of opinion on the merits of the case during inves%ga%on or trial. 15.06.2026 (DEEPAK GUPTA) Yogesh JUDGE Whether speaking/reasoned:- Yes/No Whether reportable:- Yes/No YOGESH MEHTA 2026.06.15 17:06 I attest to the accuracy and integrity of this document