CRM-M/9100/2026 of LEELA RANI Vs STATE OF HARYANA on 21 August 2026

1. First petition under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, seeking grant of anticipatory bail to the petitioner in FIR No. 378 dated 06.09.2025, registered under Sections 120-B, 420, 467, 468 and 471 of the Indian Penal Code at Police Station Sector 13-17, Panipat, along with a consequential direction to the Arresting/Investigating Officer to release the petitioner on bail in the event of her arrest in connection with the aforesaid FIR.

2. Briefly stated, the prosecution case, as emerging from the complaint lodged by complainant Pale Ram Jaglan, is that he was the recorded owner and in possession of a plot measuring 200 square yards,

-:2:- comprised in Khewat No. 1397/1509, Khasra No. 3823(5-8), situated at Pati Insar, Panipat, which was subsequently acquired by the HUDA for development of Sector 13-17, Panipat. Pursuant thereto, an award was passed in his favour by the Land Acquisition Collector, Panchkula, and compensation was paid to him. The complainant thereafter pursued his claim for allotment of a plot under the Oustees Quota and, having approached this Court by way of Writ Petition No. 1589 of 2011, obtained an order dated 25.04.2012 in his favour. He subsequently submitted further representations and, pursuant to the Oustees Policy dated 05.11.2018, applied for allotment in the 6-Marla category and deposited the requisite amount. The complainant claims to have furnished the documents sought by the HUDA/HSVP authorities from time to time; however, according to him, no plot was ultimately allotted in his favour.

2.1. It is further alleged that the acquired land comprised a larger parcel in which several other persons, including the accused Lilavati, were co-sharers and, under the applicable Oustees Policy, were independently entitled to seek allotment. According to the complainant, on 03.03.2025, when he visited the office of the HSVP, Panipat, he came to know that the accused persons, acting in concert, had allegedly procured allotment of Plot No. 539, Sector 13-17, Panipat, in the name of accused Lilavati by purportedly fabricating and misusing documents, affidavits and identity particulars bearing the complainant's name and thereafter caused the said plot to be transferred in favour of Ranbir Kundu and Kanta Kundu. The complainant asserts that he had neither executed nor furnished any such documents, affidavit or photograph for obtaining the alleged allotment and

-:3:- that the documents relied upon for the said purpose were forged and fraudulently utilised without his knowledge or consent.

2.2. On the basis of these allegations, the complainant alleged that the accused persons, pursuant to a purported conspiracy, had fabricated and utilised forged documents with the object of wrongfully securing the plot meant for him under the Oustees Quota and subsequently transferring the same in favour of other persons, thereby causing him financial and other prejudice. Consequently, he sought registration of a criminal case and appropriate legal action against the persons allegedly involved, leading to registration of the present FIR.

3. Learned counsel for the petitioner submits that the petitioner is innocent and has been falsely implicated in the present case. It is contended that the petitioner, being herself a co-sharer in the acquired land, was independently entitled to seek allotment under the Oustees Quota and, therefore, had no conceivable reason to impersonate or fabricate the identity of the complainant for securing an allotment. It is further submitted that the petitioner is an old and illiterate lady and had merely signed the affidavit and furnished the requisite documents through co-accused Ranbir Kundu and Harish Chander Satija, acting under the bona fide belief that the process was being lawfully undertaken. According to learned counsel, the subsequent allotment/re-allotment of the plot in favour of Ranbir Kundu and Kanta Kundu was effected pursuant to the consent stated to have been furnished by the petitioner, and the petitioner herself neither retained the plot nor derived any unlawful pecuniary benefit therefrom.

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3.1. It is further contended that, even as per the prosecution case, the alleged fraudulent allotment was secured in the name of Leela Rani on the strength of an allegedly forged affidavit and voter identity card purportedly belonging to complainant Pale Ram. Significantly, the identity document relied upon as that of the complainant is alleged to bear an identity number actually belonging to Rukshana wife of Salim, thereby raising a serious question regarding the origin, preparation and utilisation of the alleged forged documents and the precise role attributable to the petitioner. It is submitted that the petitioner is neither alleged to have forged the said documents nor to have personally fabricated or used the same for any independent unlawful gain. In these circumstances, custodial interrogation of the petitioner is stated to be unwarranted, particularly when the relevant documentary material is already within the domain of the investigating agency. Learned counsel accordingly prays that, without prejudicing the merits of the case, the petitioner be extended the concession of anticipatory bail.

4. Per contra, learned State counsel, assisted by learned counsel for the complainant, has vehemently opposed the prayer for anticipatory bail, contending that the petitioner is the principal beneficiary of the alleged fraud, as the allotment in question was initially secured in her name and the plot was thereafter transferred in favour of Ranbir Kundu and Kanta Kundu. It is further submitted that the documents purportedly furnished on behalf of the complainant include a forged affidavit and fabricated identity document, including the alleged voter identity card, thereby indicating deliberate manipulation of the official record. Learned

-:5:- State counsel submits that custodial interrogation of the petitioner is necessary to ascertain the identity and role of the person(s) who fabricated the complainant's signatures and identity documents and caused the same to be utilised before the competent authority. Reliance has also been placed upon the judgment of the Hon’ble Supreme Court in Pratibha Manchanda and Another vs. State of Haryana and Another, 2023 INSC 612, to contend that economic offences involving deliberate deception and manipulation of official documents warrant a cautious approach while considering the prayer for pre-arrest protection. Dismissal of the petition has accordingly been sought.

5. Having considered the rival submissions and the material available on record, it is not in dispute that the petitioner has already joined the investigation pursuant to the order dated 06.05.2026 passed by this Court. The petitioner is stated to be a lady of advanced age, aged about 70 years, and the allegations primarily revolve around the execution, submission and utilisation of documentary material in connection with the allotment and subsequent transfer of the plot. The petitioner is admittedly a co-sharer in the acquired land and claims an independent entitlement under the Oustees Policy, which aspect would necessarily require examination on the basis of the relevant record. Significantly, the petitioner had also participated in the inquiry proceedings and has already subjected herself to investigation pursuant to the interim protection granted by this Court.

5.1. In the peculiar facts and circumstances of the case, where the controversy substantially turns upon documentary evidence which is

-:6:- already within the domain of the investigating agency, no compelling circumstance has been demonstrated warranting custodial interrogation of the petitioner at this stage. The purpose of investigation can adequately be served without subjecting the petitioner to custodial restraint, particularly when she has already joined the investigation and there is no assertion of any recovery being required from her pursuant to such custody. Accordingly, the interim protection granted to the petitioner vide order dated 06.05.2026 is hereby made absolute, subject to the petitioner continuing to abide by the conditions envisaged under Section 482(2) of the Bharatiya Nagarik Suraksha Sanhita, 2023. The present petition is, accordingly, allowed.

6. In view of the final adjudication of the principal matter, all pending miscellaneous applications, if any, arising out of or ancillary to the present proceedings shall also stand disposed of accordingly. No separate or further orders are warranted in respect thereof, the same having been rendered infructuous consequent upon the disposal of the main petition.

( VIRINDER AGGARWAL) 21.08.2026

JUDGE Gaurav Sorot Whether reasoned / speaking? Yes / No Whether reportable? Yes / No