Manjeet Singh vs. State Of Punjab

Held

The Court held that the petitioner was not entitled to anticipatory bail at the current stage. The Court found that the complicity of the petitioner had been prima facie established, and the investigation was still at its threshold. Granting anticipatory bail would scuttle the ongoing investigation. The Court noted that the petitioner's conduct was "highly shady" and that he had exploited the complainant's plight in conspiracy with co-accused. The Court referred to Section 482 of the BNSS regarding directions for grant of bail and highlighted the Supreme Court's precedents in cases like State represented by CBI Vs. Anil Sharma and Gurbaksh Singh Sibbia Vs. State of Punjab, emphasizing that anticipatory bail is an extraordinary discretion to be exercised in extraordinary circumstances, considering the gravity of the offence, chances of tampering with evidence, and the probability of fleeing from justice. The Court concluded that the petitioner did not qualify for the extraordinary power of anticipatory bail.

Facts

The petitioner, Manjeet Singh, sought anticipatory bail in FIR No. 174 dated 26.09.2025, registered under Sections 318(4), 336(3), 339/340(2), 61(2) of the BNS, 2023. The FIR was lodged based on the complaint of Pushpa, who alleged that she won a lottery prize of 2.5 crores. She claimed that the petitioner and another individual, Bittu Singh, took the lottery ticket and most of the prize money, giving her only Rs. 38 lacs. The petitioner contended that he had a financial transaction with the complainant's husband and provided Rs. 2 lacs for his treatment. He further claimed that the complainant's son handed over the lottery ticket to him after receiving their share of the money, and a written agreement was made. The complainant alleged that the petitioner, in connivance with others, forged documents and encashed the prize money, misappropriating a significant portion. The petitioner's application for anticipatory bail was dismissed by the Additional Sessions Judge, Bathinda.

Key Issues

1. Whether the petitioner is entitled to anticipatory bail under Section 482 of the BNSS, considering the gravity of the alleged offence and the stage of investigation? Petitioner's Arguments: The petitioner argued that he was falsely implicated and that he had a settlement with the complainant's son, who received their entire share of the money and voluntarily handed over the lottery ticket. He claimed to be a regular GST payer and that the FIR was registered after a delay of three months due to the complainant's greed. He relied on the fact that he provided Rs. 2 lacs for the treatment of the complainant's husband. Respondent's Arguments: The State argued that there were serious allegations against the petitioner, who played a vital role in duping the complainant. They submitted that an agreement prepared by the petitioner indicated the complainant purchased the lottery ticket, a fact confessed by a co-accused. The State contended that custodial interrogation was necessary for recovery of the amount in dispute and that the petition should be dismissed.