CRM-M-30718-2026 - 1 - IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH 213 CRM-M-30718-2026 Decided on : 28.07.2026 Satnam Singh alias Kulbhushan Singh . . . Petitioner(s) Versus State of Punjab . . . Respondent(s) CORAM: HON'BLE MR. JUSTICE SANJAY VASHISTH PRESENT: ASI Varinder Singh. **** SANJAY VASHISTH , J. (Oral) On a call given by the Executive Committee of the Punjab and Haryana High Court Bar Association, the Members of the Bar have suspended the work today, i.e., 28.07.2026, and even observing a hunger strike in protest against the implementation of the Legal Aid Counsel (LADC) Policy. 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 here-under:- Name & age of Petitioner (s) FIR No. Date Section(s) Police Station District Satnam Singh alias Kulbhushan Singh 44 08.03.2026 S. 105, 126(2), 115(2), 351 & 3(5) of BNS, 2023 Bhawanigarh Sangrur 2. In the present case, on 27.05.2026, following order was passed by the Coordinate Bench of this Court:- “1. The present petition has been filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (for short - ‘the BNSS’) for grant of anticipatory bail to the petitioner in case bearing FIR No.44 dated 08.03.2026 (Annexure P-1), under Sections 105, 126(2), 115(2), 351 and 3(5) of the Bharatiya Nyaya Sanhita, 2023 (for short – ‘the BNS’) registered at Police Station Bhawanigarh, District Sangrur, Punjab. JAWALA RAM 2026.07.30 13:12 I attest to the accuracy and integrity of this document CRM-M-30718-2026 - 2 - 2. Briefly stated, the present case arose from a property dispute. Allegations qua the petitioner are that he along with co-accused armed with sticks and takua came to the house of the complainant and attacked the complainant party causing multiple injuries. Further, co- accused Mukhtiar Singh threatened father of the complainant, namely, Ajit Singh, due to which, he fell down as a result of cardiac arrest and became unconscious and was later declared dead. 3. Learned counsel for the petitioner prayed for grant of anticipatory bail to the petitioner on the following grounds: i. No offence under Section 105 of the BNS is made out from the ingredients of the FIR, as co-accused Mukhtiar Singh just threatened deceased Ajit Singh and it cannot be presumed that he had intentionally killed Ajit Singh; ii. Except Section 105 of the BNS, other offences are bailable in nature as injuries caused to the injured are simple in nature; iii. Petitioner has not extended any threat to the deceased and he has died due to cardiac arrest, as per the opinion prima facie obtained from the concerned doctor while conducting his post-mortem. iv. From the post-mortem report of the deceased, it is also clear that no one had attacked upon him, as he is not having any external injury; v. It is a version and cross-version case and the accused party also received injuries and a DDR has also been registered against the complainant party under Section 109 of the BNS. vi. Petitioner is not required for any custodial interrogation; vii. Petitioner is having clean and clear antecedents and is not involved in any other case except the present one; and viii. Petitioner is ready and willing to join the investigation and cooperate with the investigating agency. 4. Learned State counsel opposed the prayer made by the petitioner on the ground that petitioner along with co-accused caused injuries to three persons, namely, Karam Singh, Sant Singh and Mohinder Singh and all the accused threatened the deceased, due to which, he died as a result of cardiac arrest. However, he did not dispute the fact that as per his post-mortem report, the deceased has not received any injury. 5. Heard. 6. Taking into consideration the contentions of learned counsel for the parties, facts and circumstances of the present case, this Court finds merit in the present petition on the following grounds: i. Except offence under Section 105 of the BNS, all the offences are bailable in nature and it is a moot point to be considered at an appropriate stage during the course of trial as to whether commission of offence punishable under Section 105 of the BNS is made out or not; ii. It is admitted fact that the deceased did not receive any injury, as per his post-mortem report and the allegation is that co-accused, Mukhtiar Singh extended threat to the deceased, however, as per the opinion prima facie obtained from the concerned doctor, while conducting his post- mortem, he has died due to cardiac arrest; iii. It is a version and cross-version case and the accused party also received injuries and a DDR has also been registered against the complainant party; iv. Petitioner is having clean and clear antecedents and is not involved in any other case except the present one; and JAWALA RAM 2026.07.30 13:12 I attest to the accuracy and integrity of this document CRM-M-30718-2026 - 3 - v. Petitioner is ready and willing to join the investigation and cooperate with the investigating agency. 7. At this stage, the petitioner is directed to join the investigation as and when required by investigating officer. In the event of his arrest, the petitioner shall be admitted to interim bail on his furnishing bail/surety bonds to the satisfaction of investigating/arresting officer, subject to the conditions as envisaged under Section 482(2) of the BNSS [erstwhile Section 438(2) Cr.P.C.] till the next date of hearing. 8. Adjourned to 28.07.2026.” 3. From the record, and on confirming the fact from ASI Varinder Singh, it is describable that in compliance of the order dated 27.05.2026, passed by the Coordinate Bench of this Court, petitioner has joined the investigation, and has fully co-operated. Therefore, as of now, custodial interrogation of the petitioner is not required for the purpose of investigation. 4. Heard. 5. Since, petitioner has already joined the investigation and custodial interrogation is no more required; ad-interim bail order dated 27.05.2026, passed by the Coordinate Bench of this Court is hereby made absolute. 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. 6. Accordingly, petition stands disposed of, accordingly. 7. However, present order would be subject to the submission of passport of the petitioner to the Investigating Agency or to Court concerned, if he possesses, within a period of one week from today. Otherwise, he would submit an affidavit, disclosing the fact that he does not possess any passport. JAWALA RAM 2026.07.30 13:12 I attest to the accuracy and integrity of this document CRM-M-30718-2026 - 4 - It is clarified that in case, aforesaid condition is not complied with, this order would be considered as non est automatically. Pending misc. application(s), if any, also stand disposed of. (SANJAY VASHISTH) JUDGE July 28, 2026 J.Ram Whether speaking/reasoned: Yes/No Whether Reportable: Yes/No JAWALA RAM 2026.07.30 13:12 I attest to the accuracy and integrity of this document