IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH **** 108 CRM-M-34129-2026 Date of Decision.:19.06.2026 Bhupinder Punj …..Pe00oner Vs. State of Punjab .….Respondent CORAM:- HON'BLE MR. JUSTICE DEEPAK GUPTA Present:- Mr. Shubham Sharma, Advocate for the peoner. **** DEEPAK GUPTA, J. (ORAL) By way of this peon filed under Secon 482 of the BNSS, 2023, peoner prays for grant of pre-arrest bail in case FIR No.11 dated 30.11.2024 registered under Secons 384, 420, 465, 467, 468 and 120-B of IPC [corresponding to Secons 308, 318(4), 336(2), 338, 336(3) and 61 of BNS, 2023] at Police Staon Economic Offences Wing, Vigilance Bureau, District Ludhiana. 2. At the outset, it is noced that the present peon is the second a<empt by the peoner to secure the extraordinary relief of ancipatory bail in the aforesaid FIR. The record reveals that the FIR was registered on 30.11.2024. The peoner inially approached the learned Sessions Court seeking pre-arrest bail, which came to be dismissed on 16.12.2024. Therea@er, the peoner invoked the jurisdicon of this Court by filing CRM-M-65623-2024, which was dismissed vide a detailed order dated 16.01.2025 (Annexure P-2). The ma<er was then carried to the Hon’ble Supreme Court by way of a Special Leave Peon, which was also dismissed on 28.07.2025 (Annexure P-4). Not only that, the peoner subsequently filed CRM-M-59432-2025 seeking quashing of the FIR, but the said peon was withdrawn on 30.01.2026. NEETIKA TUTEJA 2026.06.19 19:15 I attest to the accuracy and integrity of this document CRM-M-34129-2026 -2- 3. The only circumstance now sought to be projected as a change warranng reconsideraon of the prayer for ancipatory bail is that the invesgaon has been completed and the final report has been presented before the competent Court. 4. This Court is unable to accept the aforesaid submission. It is a se<led principle that a second or successive peon for ancipatory bail is maintainable only upon the disclosure of a substanal and genuine change in circumstances occurring a@er the rejecon of the earlier peon. Such change must be of a nature, which materially alters the factual or legal posion considered while declining the earlier relief. Mere progression of the invesgaon to its logical conclusion or presentaon of the challan cannot, by itself, be treated as a fresh circumstance entling an accused to re-agitate a prayer which has already been declined by the Sessions Court, this Court and even the Hon’ble Supreme Court. Acceptance of such a contenon would render the doctrine governing successive bail peons wholly oose and would permit repeated ligaon on idencal grounds. 5. Rather, what is striking in the present case is that despite rejecon of the peoner's prayer for ancipatory bail at three successive judicial forums, including the Hon’ble Supreme Court, the peoner connues to remain beyond the reach of the invesgang agency. The FIR was registered in November, 2024 and more than one and a half years have elapsed therea@er. Yet no sasfactory explanaon is forthcoming as to why the peoner has not been taken into custody, if his custodial interrogaon or arrest was considered necessary by the invesgang agency. Such a state of affairs prima facie raises serious concerns regarding the manner in which the invesgaon has been conducted and the effecveness of the efforts undertaken for securing the presence of the accused. 6. This Court has repeatedly deprecated the growing tendency of ligants to file successive peons seeking ancipatory bail without any real or substanal change in circumstances. Such repeated a<empts not NEETIKA TUTEJA 2026.06.19 19:15 I attest to the accuracy and integrity of this document CRM-M-34129-2026 -3- only amount to an abuse of the process of law but also result in unnecessary consumpon of valuable judicial me. Judicial discipline and the principle of finality a<ached to earlier orders require that successive peons be entertained only in exceponal circumstances, which are conspicuously absent in the present case. 7. In view of the aforesaid facts and circumstances, finding no merit in the present peon, the same is dismissed with costs quanfied at ₹50,000/-. 8. The aforesaid amount shall be deposited by the peoner with the District Legal Services Authority, Ludhiana within a period of two weeks from today. A copy of this order be forwarded to the Chairman and Secretary, District Legal Services Authority, Ludhiana, who shall ensure compliance and shall be at liberty to iniate appropriate proceedings for recovery in accordance with law in the event of default. 9. Considering the peculiar facts noced above, parcularly the failure to secure the arrest of the peoner despite rejecon of his prayer for ancipatory bail by the learned Sessions Court, this Court and the Hon’ble Supreme Court, a copy of this order shall also be forwarded to the Director General of Police, Punjab, who shall examine the ma<er and ascertain the reasons for the apparent inacon in securing the peoner. Appropriate correcve measures, if warranted, shall be taken in accordance with law so as to ensure that judicial orders are implemented in their true le<er and spirit and that public confidence in the administraon of criminal jusce is not undermined. (DEEPAK GUPTA) JUDGE June 19, 2024 Neeka Tuteja Whether Speaking/reasoned Yes/No Whether Reportable Yes/No NEETIKA TUTEJA 2026.06.19 19:15 I attest to the accuracy and integrity of this document