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CRM-M-33799-2026 [1] IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
CRM-M-33799-2026 Date of decision: 15.06.2026 Parminder Singh Sangwan ...Pe$$oner Versus State of Haryana ...Respondent
CORAM:
HON'BLE MR. JUSTICE DEEPAK GUPTA Present: Mr. V.P. Sangwan, Advocate for the pe$$oner. **** DEEPAK GUPTA, J. (ORAL) By way of the present pe$$on filed under Sec$on 482 of the Bhara$ya Nagarik Suraksha Sanhita, 2023, the pe$$oner seeks grant of an$cipatory bail in case FIR No.235 dated 17.10.2025 registered under Sec$ons 229(2), 318(4), 336(2), 336(3) and 340 of the Bhara$ya Nyaya Sanhita, 2023 (corresponding to Sec$ons 193, 420, 465, 468 and 471 IPC) at Police Sta$on Bhiwani Civil Lines, District Bhiwani.
2.
Learned counsel for the pe$$oner contends that the pe$$oner has been falsely implicated in the present case. It is submi;ed that the pe$$oner had never prepared or inten$onally submi;ed any forged document before the Court. According to the learned counsel, the pe$$oner had suddenly fallen ill and had visited CHC Manoharpur, Jaipur, where he was allegedly advised bed rest for three days. It is further argued that the prosecu$on case rests en$rely on documentary evidence, which is already in possession of the inves$ga$ng agency and forms part of the Court record. Therefore, no recovery remains to be effected from the pe$$oner and custodial interroga$on is not required. Learned counsel submits that the pe$$oner is ready to join inves$ga$on and cooperate with YOGESH MEHTA 2026.06.16 15:31 I attest to the accuracy and integrity of this document
CRM-M-33799-2026 [2] the inves$ga$ng agency and, therefore, deserves the concession of an$cipatory bail. 3. I have heard learned counsel for the pe$$oner and perused the paper-book. 4. The record reveals that Criminal Appeal No. CRA-25-2025 filed by the pe$$oner was listed before the learned Addi$onal Sessions Judge, Fast Track Court under the POCSO Act, Bhiwani on 10.09.2025. On the said date, the pe$$oner did not appear before the Court and instead sought exemp$on from personal appearance through his counsel by asser$ng that he was suffering from illness. In support of such prayer, a medical cer$ficate purportedly issued by a doctor of CHC Manoharpur, Jaipur was produced before the Court. 5. The learned Appellate Court no$ced discrepancies in the document and entertained doubts regarding its authen$city. Consequently, no$ce was issued to the concerned doctor. Upon appearance, the doctor categorically stated that the cer$ficate neither had been issued by him nor did it bear his signatures. It was thus prima facie found that the medical cer$ficate relied upon by the pe$$oner for securing exemp$on from appearance was a forged document. On the basis of the complaint made by the Reader of the Court, the present FIR came to be registered. 6. The allega$ons against the pe$$oner are of a serious nature. The accusa$on is not merely that a forged document was created, but that such document was consciously produced before a Court of law with the object of obtaining a judicial order. Any a;empt to mislead a Court by producing fabricated documents strikes at the very founda$on of the administra$on of jus$ce and cannot be viewed lightly.
Offences rela$ng to fabrica$on and use of forged documents in judicial proceedings have a YOGESH MEHTA 2026.06.16 15:31 I attest to the accuracy and integrity of this document
CRM-M-33799-2026 [3] direct bearing upon the sanc$ty and purity of the judicial process. 7. The conten$on that the case is based on documentary evidence and, therefore, custodial interroga$on is unnecessary, cannot be accepted at this stage. The inves$ga$on is required to ascertain the source from which the forged cer$ficate was procured, the iden$ty of the person who prepared it, the manner in which it came into the possession of the pe$$oner and whether any other persons were involved in the commission of the alleged offences. These aspects can be effec$vely inves$gated only through a thorough interroga$on of the accused and other connected persons. The mere fact that the forged document is available on record does not render the inves$ga$on complete. 8. The power to grant an$cipatory bail is extraordinary in nature and is required to be exercised cau$ously, par$cularly where the allega$ons disclose deliberate interference with the due administra$on of jus$ce. While personal liberty is undoubtedly a valuable right, the same must be balanced against the societal interest in ensuring a fair and effec$ve inves$ga$on into offences involving fabrica$on of evidence and use of forged documents before judicial forums. 9. This Court is of the considered opinion that the allega$ons levelled against the pe$$oner disclose a prima facie case. The inves$ga$on is s$ll at a stage where the source and authorship of the forged cer$ficate are required to be unearthed. Grant of an$cipatory bail at this stage may impede the inves$ga$on and frustrate efforts of the inves$ga$ng agency to trace the origin of the forged document and iden$fy all persons involved in the commission of the alleged offences. 10.
Having regard to the nature and gravity of the accusa$ons, the apparent misuse of a forged document in judicial proceedings and the YOGESH MEHTA 2026.06.16 15:31 I attest to the accuracy and integrity of this document
CRM-M-33799-2026 [4] necessity of a complete and effec$ve inves$ga$on, this Court does not find it to be a fit case for grant of an$cipatory bail. 11. Consequently, the present pe$$on is dismissed. 12. However, any observa$on made herein shall be construed only for the purpose of deciding the present pe$$on and shall not be treated as an expression 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 2026.06.16 15:31 I attest to the accuracy and integrity of this document