Punjab and Haryana High Court

CRM-M/33165/2026 of PRIYANSHU SHARMA ALIAS PRINCE Vs STATE OF HARYANA AND ANOTHER on 3 September 2026

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COURT OF PUNJAB AND HARYANA AT 101 Priyanshu Sharma alias Prince State of Haryana and another Date of decision: Date of Uploading : 0 CORAM: Present: SUMEET GOEL 1. the Bharatiya Nagarik Suraksha Sanhita, 2023 ‘ the BNSS’) FIR No. 43 dated 22.04.2026 registered under Sections 120 506

CRM-M-

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Priyanshu

State of H

Date of d

Date of U

CORAM

Present:

SUMEET

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1. the Bhara ‘the BNS FIR No. 4 506 of IPC

arrest/anti on 15.05.2

2. present p anticipato under law -33165-2026 THE HIGH COURT OF PUN CHANDIG

u Sharma alias Prince V/s Haryana and another decision: 03.09.2026 Uploading : 07.09.2026 M: HON’BLE MR. JUSTICE Mr. Kanwar Abhay Singh, A Mr. Gurmeet Singh, AAG Ha Mr. Navjit Singh, Advocate f ***** T GOEL, J. (Oral) The present petition is the se atiya Nagarik Suraksha Sanhita, S’) for grant of pre-arrest/anticip 43 dated 22.04.2026 registered u C at Police Station Naggal, Distr The petitioner had earlie icipatory bail before this Court w 2026. The relevant part of said o “2. Learned counsel appearin some time, seeks to withdraw the p

3. Ordered accordingly.” At the outset, it deserves petition is a second attempt ory bail. A second anticipatory b w; however, it requires demons

NJAB AND HARYANA AT ARH

CRM-M-33165-2026

....Petitioner

....Respondents SUMEET GOEL Advocate for the petitioner. aryana. for respondent No.2 econd attempt under Section 482 2023 (hereinafter to be referred patory bail to the petitioner in ca under Sections 120-B, 406, 420 a rict Ambala. er applied for grant of p which was dismissed as withdra order reads as under:- ng for the petitioner, after arguing petition in hand.

to be mentioned herein that by the petitioner for grant bail petition is indeed maintaina stration of a substantial change

2 of d as ase and pre- wn for the of ble in AJAY KUMAR

CRM-M- circumsta propositio superficia that the re filings bu the initial be made t State of H under:- -33165-2026 ances since the dismissal of th on of law that such change mu al or technical, to warrant recon emedy of successive bail petition ut is available only when new a l assessment of the case. A prof to the judgment passed by this Haryana, 2024(3) RCR(Crimin “11.

As an epilogue to principles emerge: I Second/successive Section 438 of Cr.P.C., 19 petition ought not to b maintainability thereof. II Such second/succ maintainable whether withdrawn/dismissed as no or earlier petition was dism III For the second/su succeed, the petitioner/ap required to show subst showing of a mere supe suffice. IV No exhaustive gui what would constitute su every case has its own u this issue is best left to th Court dealing with suc petition(s). V In case a Cour anticipatory bail petitio pertinently required to be such a plea being second he earlier petition. It is a sett ust be significant and not mer nsideration. This standard ensu ns is not misused through repea and material factors arise that al fitable reference in this regard c Court titled as Bhisham Singh nal) 65, relevant whereof reads o the above rumination, the follow anticipatory bail petition(s) filed un 973 is maintainable in law & hence s be rejected solely on the ground cessive anticipatory bail petition(s) earlier petition was dismissed ot pressed/dismissed for non-prosecut missed on merits. uccessive anticipatory bail petition(s) pplicant shall be essentially/pertinen tantial change in circumstances a rficial or ostensible change would idelines can possibly be laid down as ubstantial change in circumstances unique facts/circumstance. According he judicial wisdom and discretion of ch second/successive anticipatory b rt chooses to grant second/success on(s), cogent and lucid reasons recorded for granting such plea desp d/successive petition(s). In other wor

led ely ures ted lter can vs. as wing nder uch of ) is as tion ) to ntly and not s to as gly, f the bail sive are pite rds, AJAY KUMAR

CRM-M-

as withdr grant of a substantia indicate t grant of forward in so as to e bail petit dismissed this Court well whic connected State of H

Septembe Ajay

-33165-2026 the cause for countenanced/entertained ought to be readily and c passed. VI Once a plea for a withdrawn/dismissed as no or dismissed on merits by anticipatory bail petition Court.” The first anticipatory bail fil rawn on 15.05.2026. The insta anticipatory bail has been filed t al change in circumstance has b that the petitioner is entitled to anticipatory bail. From the e n the present petition, no fresh g enable the petitioner to file and tion. However, since the firs d as withdrawn and there was n t deems it appropriate to decide t ch has been adjudicated upon a d petition i.e. CRM-M-31351-2 Haryana and another of even da

er 03, 2026 Whether speaking/reasoned: Whether reportable:

a Court having successfu d such second/successive petition clearly decipherable from the said or anticipatory bail has been dismissed ot pressed/dismissed for non-prosecut y the High Court, no second/success n(s) shall be entertained by a Sessi led by the petitioner was dismiss ant petition i.e. second petition hereafter on 05.06.2026. No fre been brought forward which wou o maintain his second petition entire factual conspectus broug ground or circumstance is made o d maintain the second anticipato st anticipatory bail petition w no adjudication on merits there the instant one on merits thereof and dismissed by this Court in 2026 titled as Karam Chand ate. (SUMEET GOEL)

JUDGE

Yes/No

Yes/No

fully n(s) rder d as tion sive ions sed for esh uld for ght out ory was eof, f as the vs. AJAY KUMAR

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