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CRM-M-34551-2026 (O&M) 1 IN THE HIGH COURT OF PUNJAB & HARYANA AT CHANDIGARH. 221 CRM-M-34551-2026 (O&M). Date of Decision: 27.07.2026. Swati Bhati ....Petitioner. VERSUS State of Haryana ....Respondent. **** CORAM : HON'BLE MR. JUSTICE SANJAY VASHISTH --- Present: Mr. Akshit Mehta, Advocate and Mr. Shubham Raj Srivastav, Advocate for the petitioner. Ms. Malvika Singh, Deputy Advocate General, Haryana. Mr. Manu Loona, Advocate for the complainant. **** SANJAY VASHISTH, J. (Oral)
1. Prayer in this petition, filed under Section 482 of the BNSS, 2023 (earlier Section 438 Cr.P.C.), is for grant of anticipatory bail to the petitioner, who has been booked in a criminal case arising out of First Information Report, as detailed hereunder:- Name of petitioner(s) FIR No. Date Section(s) Police Station District Swati Bhati 568 03.09.2024 408, 420, 120-B IPC (467, 468, 471, 201 IPC added later on) Sadar, Gurugram Gurugram
2. On 24.06.2026, following order was recorded:-
“Inter alia contends that in the present case, the petitioner has been implicated solely on account of the fact that she is the wife of Amit Punia, who was as per the FIR an employee of the complainant company. It is submitted that there was no privity of contract between the petitioner and JITENDER 2026.07.27 19:10 I attest to the accuracy of this document
CRM-M-34551-2026 (O&M) 2 the company in question and the petitioner was not an employee of the said company and there is no allegation of any fraudulent inducement on behalf of the petitioner. It is submitted that as per the allegations in the FIR, some amount has been transferred in the account of the petitioner but the same has been done by the husband of the petitioner whom the petitioner has every valid reason to believe was working for the company in question. It is further submitted that similar allegation has been made against co-accused Usha Bhati, who is the mother-in-law of Amit Punia and it has been stated in the FIR that amount was also transferred in her account. It is submitted that the said Usha Bhati had applied for anticipatory bail and a coordinate Bench of this Court vide order dated 10.11.2025 passed in CRM-M-34414- 2025 was pleased to grant anticipatory bail to said Usha Bhati. It is submitted that the petitioner is not involved in any other case. Notice of motion for 27.07.2026.
In the meantime, in the event of arrest, the Investigating/ Arresting Officer shall release the petitioner on interim bail on furnishing personal/surety bonds to his satisfaction. The petitioner shall also abide by the conditions as envisaged under Section 482(2) of the BNSS, 2023.”
3. Continuing the submissions, learned counsel for the petitioner contends that in compliance of the order dated 24.06.2026, passed by this Court, petitioner has joined the investigation, and has fully co-operated. Therefore, learned counsel prays for confirmation of the said interim anticipatory bail order. 4. Learned State counsel on instructions, confirms the said averment made by counsel for the petitioner of joining the investigation by the petitioner, and submits that as of now, custodial interrogation of the petitioner is not required for the purpose of investigation. 5. Heard learned counsel for the parties. 6. Since, petitioner has already joined the investigation and custodial interrogation is no more required; ad-interim bail order dated 24.06.2026, passed by this Court is hereby made absolute. Accordingly, present petition is allowed. JITENDER 2026.07.27 19:10 I attest to the accuracy of this document
CRM-M-34551-2026 (O&M) 3 However, petitioner shall continue to join the investigation as and when required to do so and abide by all the terms and conditions laid down under Section 482(2) of BNSS, 2023. 7. Besides, it is directed that petitioner would hand over her passport to the Investigating Agency or to Court concerned, if she possesses. Otherwise, would submit an affidavit, disclosing the fact that she does not possess any passport. 8. Accordingly, petition stands disposed of. (SANJAY VASHISTH) JUDGE 27.07.2026 jitender Whether speaking/ reasoned : Yes/ No Whether Reportable : Yes/ No JITENDER 2026.07.27 19:10 I attest to the accuracy of this document