BAIL APPLN./3410/2026 of ANNU DHANKAR Vs STATE (NCT OF DELHI) on 19 August 2026

1. The accused/applicant seeks regular bail in case FIR No. 355/2024 of PS Special Cell for offence under Section 302/120B/174A/419/420/468/34 IPC.

2. Learned APP for State assisted by Investigating Officer/Inspector Satbir Singh accepts notice and strongly opposes the bail application.

3. Broadly speaking, the allegation against the accused/applicant is as GIRISH KATHPALIA

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0996b40f80cbd2eee60402c487965ff801e26fa , cn=GIRISH KATHPALIA Date: 2026.08.19 17:07:51 +05'30'

follows. The accused/applicant honey-trapped the deceased and called him to a restaurant in Rajouri Garden on 18.06.2024, where the shooters namely Ashish and Vikas fired multiple rounds of bullets, causing instant death of the deceased. The shooters Ashish and Vikas were killed later in an encounter, as informed by the IO/Inspector Satbir Singh. The killing of the deceased in the present case was done on instructions of accused Himanshu and Sahil, both of whom are proclaimed offenders, now hiding somewhere in the USA. The present accused/applicant also was declared as a proclaimed offender, after which she was apprehended from Lakhimpur, UP on 26.10.2024 when she was trying to flee away to Nepal.

4. On behalf of accused/applicant, it is submitted that the only ground being raised in this application is the failure of the IO to supply grounds of arrest to the accused/applicant. It is submitted by learned counsel for accused/applicant that there were two arrest memos pertaining to the accused/applicant, one of which was on the basis of DD No. 4A while the other one was on the basis of the present case. In the arrest memo related to the present case also, the grounds of arrest were not mentioned, so the accused/applicant deserves to be released on bail.

5. Learned APP for State places reliance on the judgment of this Court in the case of Amar Thapa vs. State of NCT of Delhi, 2026:DHC:5520, contending that the legal position as described in the said case remains unsettled till date. It is submitted by learned APP that the accused/applicant GIRISH KATHPALIA

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was arrested on 25.10.2024 in DD No. 4A whereas the impact of non-supply of written grounds of arrest was elucidated with clarity in the case of Mihir Rajesh Shah vs. State of Maharashtra & Anr., 2025:INSC:1288, much later on 06.11.2025. Further, it is also argued by learned APP that no prejudice was caused to the accused/applicant on account of the alleged non- supply of grounds of arrest.

6. To recapitulate, in the present case, the accused/applicant was arrested on 25.10.2024 on the basis of DD No. 4A as she had been declared a proclaimed offender. The accused/applicant had been declared proclaimed offender after applying the procedure established by law, wherein initially non-bailable warrants were issued, but since the same could not be executed, proclamation proceedings under Section 82 CrPC were carried out by the court of competent jurisdiction. It was not a case of direct arrest of the accused/applicant in the course of investigation. The arrest memo clearly informed the accused/applicant that she was being arrested because she had been declared a proclaimed offender and that intimation, in view of legal position discussed in Amar Thapa (supra) is adequate compliance.

7. As mentioned above, no prejudice has been shown to have been caused to the accused/applicant, even if it is assumed to be a case of failure to furnish grounds of arrest. Admittedly, on the very first occasion after her arrest, when the accused/applicant was brought before the concerned court, she was equipped with legal assistance and in the first order dated GIRISH KATHPALIA

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96b40f80cbd2eee60402c487965ff801e26fa, cn=GIRISH KATHPALIA Date: 2026.08.19 17:07:32 +05'30'

26.10.2024, the learned Magistrate specifically recorded that the information of arrest had been supplied to also brother of the accused/applicant; and even the application of the IO for formal interrogation and arrest which mentioned in detail the circumstances, was allowed by the learned Magistrate by that order in presence of counsel for the accused/applicant.

8. Besides the aforesaid, it would also be significant to keep in mind that the accused/applicant not just honey-trapped the deceased in the present case, she also has adopted multiple false identities while residing at different places across the country, as enumerated in order dated 05.06.2026 passed by the learned Court of Sessions while dismissing her bail application.

9. Considering the above factors, I do not find it a fit case to release the accused/applicant on bail. The bail application and the accompanying application are dismissed.

10. Copy of this order be sent to the concerned Jail Superintendent for being conveyed to the accused/applicant immediately.

GIRISH KATHPALIA (JUDGE) AUGUST 19, 2026/dr GIRISH KATHPALIA

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96b40f80cbd2eee60402c487965ff801e26fa, cn=GIRISH KATHPALIA Date: 2026.08.19 17:07:21 +05'30'