Satgur Singh vs State of Punjab

The instant petition has been filed under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (for short ‘BNSS’) seeking grant of anticipatory bail to the petitioner in case bearing FIR No.194 dated 29.06.2026, registered under Sections 420, 406 and 120-B of IPC at Police Station Lehra, District Sangrur.

Brief facts of the case relevant for the purpose of disposal of this petition are that the aforementioned FIR has been registered at the instance of complainant Manpreet Singh alleging therein that in the year 2016, the petitioner along with Ajay Kumar Rangra and Mohan Singh had committed fraud upon him to the tune of Rs.20 lakhs on the pretext of securing his recruitment as a driver in the Punjab Police. It was alleged that the accused showed him a fake list of driver constables in which his name was reflected and represented that on account of their access to higher officials, they could secure his recruitment. It was further alleged that on the aforesaid representation, he paid Rs.1 lakh to Ajay Kumar Rangra through Google Pay and the remaining amount in cash. When the complainant came to know that he had been cheated, he demanded return of the money, on which, the petitioner and co-accused Mohan Singh returned a sum of Rs.13 lakhs to him. The complainant alleged that an amount of Rs.7 lakhs, along with interest, was still unpaid. It was further alleged that when the complainant sought the remaining amount and took legal action, the petitioner and co-accused compelled him to withdraw his application and extended threats to his life and property. The complainant also referred to an earlier application submitted by him on 26.03.2025, pursuant to which a compromise was arrived at on 10.04.2025 and three cheques, totalling Rs.11.50 lakhs towards the remaining amount and interest, were issued but the cheques were dishonoured. After registration of the FIR, investigation proceedings have been initiated and the same are underway. Apprehending his arrest, the petitioner moved an application for grant of anticipatory bail, which has been dismissed by the Court of learned Additional Sessions Judge, Sangrur, vide order dated 13.08.2026.

It is argued by learned counsel for the petitioner that he has been falsely implicated in this case. He has no role in the alleged financial transaction between the complainant and co-accused Ajay Kumar Rangra. It is further argued that the petitioner never promised the complainant any employment and never received any money from him. The compromise dated 10.04.2025 was principally between the complainant and Ajay Kumar Rangra and the petitioner merely signed the same as an attesting witness. The three cheques referred to therein were also issued from the account of Ajay Kumar Rangra. Learned counsel further submits that co-accused Ajay Kumar Rangra has specifically stated before the police as well as in a subsequent affidavit that the petitioner had no involvement in the transaction. It is argued that the present FIR is a counterblast to FIR No.222 dated 17.09.2025, registered against the complainant on the complaint of the petitioner's brother-in-law, and that the dispute is civil in nature. It is also submitted that the investigation is based upon documentary evidence already available with the investigating agency. No recovery is to be effected from the petitioner. He is ready to join the investigation. His custodial interrogation is not required. Hence, it is urged that the petition deserves to be allowed.

Notice of motion.

Learned State counsel has advance notice of the petition and is ready to argue the matter. At this stage, Mr. Maninder Singh Saini, Advocate has caused appearance on behalf of the complainant and has filed his Vakalatnama.

Learned State counsel, assisted by learned counsel for the complainant, has opposed the prayer of the petitioner by submitting that the allegations against the petitioner are specific and serious in nature. He is directly named in the FIR as one of the persons who, along with the co-accused, induced the complainant to part with Rs.20 lakhs on the false promise of securing his recruitment in the Punjab Police. The compromise relied upon by the petitioner does not wipe out the allegations contained in the FIR, particularly when the alleged cheques issued pursuant thereto were dishonoured. The matter relates to an alleged job-procurement racket involving recruitment in the police and the possibility of involvement of other persons cannot be ruled out at this stage. Custodial interrogation of the petitioner is must for conducting proper investigation in the matter. Hence, it is urged that the petition is liable to be dismissed.

This Court has heard the rival submissions.

The petitioner along with the co-accused is alleged to have induced the complainant to part with a sum of Rs.20 lakhs on the false promise of securing his recruitment as a driver in the Punjab Police. A specific role has been attributed to the petitioner in the alleged transaction. It is undisputed that a sum of Rs.13 lakhs was subsequently returned to the complainant through the petitioner/co-accused. The contention that the petitioner had no role in the transaction and that the dispute is essentially between the complainant and the co-accused involves disputed questions of fact, which cannot be conclusively examined at the stage of consideration of anticipatory bail. The allegations are serious in nature and the investigation is still in progress. Keeping in view the specific role attributed to the petitioner, the nature of allegations and the requirement of effective investigation, his custodial interrogation cannot be ruled out. In case his custodial interrogation is denied to the investigating agency, the same will leave many glaring loopholes and gaps adversely affecting the investigation. The powers under Section 482 of BNSS are extraordinary and the same are to be exercised sparingly in exceptional circumstances. However, in the present case, no such exceptional circumstances warranting exercise of the powers for grant of anticipatory bail by this Court are existing. As such, this Court is of the considered opinion that the petition does not deserve to be allowed. Accordingly, the same is dismissed.

It is made clear that the observations made hereinabove are only for the purpose of deciding the present petition and the same shall not be construed as an expression of opinion on the merits of the case.