IN THE HIGH COURT FOR THE STATES OF PUNJAB AND

HARYANA AT CHANDIGARH

CRM-M No.__________ of 2025

MEMO OF PARTIES

Manoj Kumar aged about 40 years, S/o Sh. Abhay Singh, R/o

H.No.215, Near Mata Chowk, Chandpur, District Faridabad,

Haryana (Aadhar No.326555038177) (Mob. No.9315990733)

…Petitioner

(Whether petitioner has been declared as proclaimed

offender: No)

Versus

State of Haryana

…Respondent

CHANDIGARH
DATED: 26.05.2025
[RAM BHATI] [NARESH K. CHHOKAR]
ADVOCATES
COUNSELS FOR THE PETITIONER
 First petition under Section 482 of BNSS 2023

for grant of Anticipatory Bail to the petitioner in

the case bearing FIR No.11, dated 11.01.2025

under Section 316(2), 318(4), 319(2), 61 of BNS

2023(338, 336(3), 340(2) of BNS 2023 added

later on) registered at Police Station sector-17,

District Faridabad, Haryana.

AND/OR

It is further prayed that this Hon’ble Court may

kindly be issue any other order or direction,

which this Hon’ble Court may deem fit and

proper keeping in view the facts and

circumstances of the case.

RESPECTFULLY SHOWETH:-

1. That the petitioner is a law-abiding and peace-loving

citizen of India, having deep respect for the law and the

Constitution. He has been falsely implicated in the

present case and has no connection whatsoever with the

alleged incident. The petitioner submits that he is

innocent and has been dragged into this case on baseless

and unfounded allegations. A true and translated copy of

the First Information Report (FIR) bearing No. 11, dated

11.01.2025, registered under Sections 316(2), 318(4),

319 and 61 of the Bharatiya Nyaya Sanhita, 2023, at

 Police Station Sector-17, District Faridabad, Haryana, is

annexed herewith and marked as ANNEXURE P-1.

2. That the crux of the allegation, as set out in the

complaint, is that the accused persons entered into a

criminal conspiracy to defraud the complainants of a sum

of Rs. 1 crore under the false pretense of effecting a sale

of land situated at Zaidapur, Palwal-Sohna Road, Palwal.

In furtherance of this conspiracy, the accused purportedly

presented forged and fabricated documents in the name

of one Mrs. Hardei, and, by impersonating her and her

alleged family members, misled the complainants into

believing that the proposed transaction was genuine.

Relying on these misrepresentations, the complainants

parted with a total sum of Rs. 1 crore—comprising Rs.

2,00,000/- in cash, Rs. 54,00,000/- via RTGS, and a post-

dated cheque of Rs. 44,00,000/-. The said amounts were

deposited into Account No. 7405000100080999

maintained at Punjab National Bank, Tigaon Branch,

which was falsely claimed to belong to Mrs. Hardei.

Subsequent inquiries revealed that the actual owners of

the land had neither sold the property nor authorised any

individual to act on their behalf, thereby establishing the

fraudulent and deceitful nature of the transaction. In light

of these facts, the complainants have sought the

registration of an FIR against all persons named in the

 complaint under the relevant provisions of the Bhartiya

Nyaya Sanhita, including Sections pertaining to cheating,

criminal conspiracy, forgery, impersonation, and criminal

misappropriation."

3. That after the registration of the FIR in question, the

investigation was set in motion. During the course of the

investigation, additional sections, namely Sections 338,

336(3), and 340(2) of the Bharatiya Nyaya Sanhita, 2023,

were added in the array of the section. On 12.03.2025,

one of the accused, namely Sandeep @ Sanju, was

arrested, and his statement was disclosure recorded was

recorded by the investigating agency, while he was

languish in the police custody, thus the disclosure

statement made in the police custody does not carry any

value nor is admissible in evidence.

It is pertinent to mention that the name of the present

petitioner surfaced for the first time in the said disclosure

statement. However, the said disclosure statement does

not contain any reference to any specific allegation, role,

any transactions and any amount or any other concrete

or reliable evidence that could implicate the petitioner.

The only mention made by the said accused relates to a

General, omnibus, vague statement about his friendship

with the petitioner. It is further submitted that prior to the

arrest of Sandeep @ Sanju, several other co-accused had

 already been arrested, and none of them had ever named

or implicated the present petitioner in any manner

whatsoever in the present case.

4. That it is further submitted that the name of the

petitioner does not find mention in the FIR. His name

surfaced for the first time in the disclosure statement of

the co-accused Sandeep @ Sanju. As per the version of

the prosecution, the petitioner was allegedly in contact

with another co-accused, namely Rajesh, and his mobile

location was reportedly found to be in the vicinity of the

place of occurrence, where the alleged payment was

made to the accused persons. However, it is respectfully

submitted that mere location proximity or alleged

contact, without any corroborative evidence, is not

sufficient to establish the petitioner’s involvement in the

alleged offence.

Moreover, the mere levelling of allegations cannot and

must not be equated with proof. Allegations, in the

absence of any documentary or corroborative evidence,

hold no legal or evidentiary value. It is a fundamental

principle of justice that no adverse inference can be

drawn, nor can the concession of interim bail be denied,

solely on the basis of unsubstantiated claims. Such a

denial would be arbitrary, unjust, and contrary to the

established norms of due process.

5. That the petitioner had approached the Hon’ble Court of

the learned Additional Sessions Judge, Faridabad, seeking

the concession of anticipatory bail in connection with the

present case. However, the learned Additional Sessions

Judge, vide order dated 17.05.2025, dismissed the

anticipatory bail application without assigning any

cogent, convincing, or legally sustainable reasons. The

impugned order is devoid of judicial reasoning and fails to

demonstrate a proper application of mind. It neither

considers the absence of direct or corroborative evidence

against the petitioner nor evaluates the factual matrix in

a fair or balanced manner. Moreover, the order stands in

stark contradiction to the settled law of the land and the

ratio decidendi laid down by the Hon’ble Apex Court in a

catena of authoritative judgments, which consistently

emphasize that anticipatory bail cannot be denied merely

on the basis of unsubstantiated allegations, especially

when no prima facie case is made out. The failure to

adhere to these well-established legal principles renders

the impugned order legally unsustainable and arbitrary..

A photocopy of the said impugned order dated

17.05.2025 is annexed herewith and marked as

ANNEXURE P-2.

6. That it is most respectfully submitted that the petitioner

has absolutely no involvement—direct or indirect—in the

alleged transaction that forms the basis of the present

case. He is neither a property dealer by profession nor

was he associated in any official or unofficial capacity

with the purported property deal. He is not the vendor

who sold the property, nor the vendee who purchased it.

He has not signed any document, contract, agreement, or

receipt related to the said transaction. There is no

evidence on record, oral or documentary, that would

establish even a remote connection between the

petitioner and the alleged deal.

Importantly, the petitioner has not acted as a

middleman, broker, facilitator, or agent in any manner.

He has not arranged the meeting of the parties,

facilitated any payment, or played any role in the

negotiation or execution of the deal. There is also no

allegation or evidence suggesting that he has received

any part of the sale consideration, commission, or any

other form of financial gain from the said transaction. The

financial trail—if any exists—completely excludes the

petitioner.

Despite this complete lack of involvement, the

petitioner’s name has been needlessly and unjustifiably

included in the present case, without any cogent reason

or evidentiary foundation. His implication appears to be

based solely on unverified assumptions or conjectural

inferences rather than any substantive material. Such an

approach not only undermines the credibility of the

investigative process but also results in gross injustice to

an individual who has no nexus with the offence alleged.

Under settled principles of criminal jurisprudence,

mere suspicion, in the absence of prima facie evidence,

cannot form the basis of criminal prosecution or justify

the denial of personal liberty. The Hon’ble Supreme Court

has time and again held that liberty is the most cherished

fundamental right under Article 21 of the Constitution,

and any curtailment of the same must be justified by

strong and credible reasons. In the instant case, where no

role—overt or covert—can be attributed to the petitioner,

subjecting him to custodial interrogation would serve no

legitimate purpose. It would not further the investigation

in any meaningful way and would only amount to

unwarranted harassment and humiliation.

Therefore, in light of the above facts and the

complete absence of incriminating material, the petitioner

deserves the protection of anticipatory bail. The denial of

such protection would not only be unjust but would also

run contrary to the constitutional safeguards available to

every citizen against arbitrary arrest and detention

7. That Section 25 of the Indian Evidence Act, 1872, imposes

an absolute bar on the admissibility of confessions made

to a police officer, safeguarding the accused’s right

against self-incrimination and preventing misuse of

custodial authority. As clarified in Tofan Singh v. State

of Tamil Nadu [(2021) 4 SCC 1], this prohibition

extends to officers under special statutes deemed “police

officers,” rendering such confessions inadmissible unless

they fall within the narrow exception of Section 27. Under

Section 27, only a disclosure statement leading to the

discovery of a new fact is admissible, and even then, only

to the extent of the discovery, as established in Pulukuri

Kottaya v. Emperor (AIR 1947 PC 67). Courts must

rigorously scrutinize such statements for voluntariness

and corroboration to ensure their reliability.

In the instant case, the prosecution’s reliance on an

alleged disclosure statement to oppose pre-arrest bail in

FIR No. 11, dated 11.01.2025, registered under Sections

316(2), 318 (4), 319, and 61 of the Bharatiya Nyaya

Sanhita, 2023, at Police Station SECTOR-17, Faridabad,

Haryana, is fundamentally flawed. The statement,

purportedly recorded under Section 27, fails to meet the

statutory threshold as it has not led to any material

discovery, nor is it corroborated by independent

evidence. Furthermore, the circumstances of its

recording, lacking demonstrable voluntariness, render it

presumptively unreliable under the principles laid down in

Tofan Singh. Consequently, the statement cannot form

the basis for a prima facie case against the petitioner.

The evidentiary weakness of the alleged disclosure

statement strongly supports the grant of pre-arrest bail

under Section 482 of the Bharatiya Nagarik Suraksha

Sanhita, 2023. As held in Gurbaksh Singh Sibbia v.

State of Punjab (AIR 1980 SC 1632), pre-arrest bail is

warranted to protect individuals from unwarranted arrest

where the prosecution’s case lacks credible evidence. The

petitioner, a law-abiding citizen with no prior criminal

record, faces false implication in a case resting on an

inadmissible or unreliable disclosure statement. Denying

bail would result in undue harassment and an unjust

curtailment of liberty, contrary to the principles of justice.

Thus, pre-arrest bail is essential to prevent misuse of the

legal process.

The alleged disclosure statement attributed to the

petitioner, purportedly recorded under Section 27 of the

Indian Evidence Act, 1872, is devoid of any substantive

evidentiary value so as to justify the denial of pre-arrest

bail. It is a settled principle of law, as laid down by the

Hon’ble Privy Council in Pulukuri Kottaya v. Emperor

(AIR 1947 PC 67), that a disclosure statement under

 Section 27 is admissible only to the limited extent that it

leads to the discovery of a relevant fact. Furthermore,

such a statement must be voluntary and free from any

form of coercion or inducement.

In the present case, the prosecution's reliance on

the alleged disclosure statement is wholly misplaced, as

the statement is not corroborated by any independent or

reliable evidence. Additionally, the circumstances under

which the statement was recorded raise serious doubts

about its authenticity and voluntariness, rendering it

inherently unreliable.

In view of the petitioner’s prima facie case of false

implication, the weak and unsubstantiated nature of the

prosecution’s case, and the absence of any material

justifying custodial interrogation, it is respectfully

submitted that the petitioner deserves the protection of

pre-arrest bail. Relief under Section 482 of the Bharatiya

Nagarik Suraksha Sanhita, 2023, is therefore warranted

to safeguard the petitioner from unnecessary harassment

and infringement of his personal liberty.

The grant of pre-arrest bail under Section 482 of the

Bharatiya Nagarik Suraksha Sanhita, 2023, is guided by the

principles laid down in Gurbaksh Singh Sibbia v. State of

Punjab (AIR 1980 SC 1632), which emphasize protecting

individual liberty against unwarranted arrests, particularly in

cases of alleged false implication. In Arnesh Kumar v. State

of Bihar [(2014) 8 SCC 273], the Hon’ble Supreme Court

mandated that arrests should not be routine, especially for

offenses punishable by up to seven years’ imprisonment,

requiring the police to issue a notice under Section 35 of BNSS

(erstwhile Section 41A of CrPC) and justify the necessity of

arrest. These safeguards ensure that the power of arrest is

exercised judiciously, balancing investigative needs with the

accused’s fundamental rights.

In the present case, the petitioner seeks pre-arrest bail in

connection with FIR No. 11, dated 11.01.2025, registered

under Sections 316(2), 318(4), 319, and 61 of the Bharatiya

Nyaya Sanhita, 2023, at Police Station SECTOR-17, Faridabad,

Haryana. The offense under Section 318(4), punishable by up

to seven years, falls squarely within the ambit of Arnesh

Kumar, necessitating compliance with Section 35 BNSS. The

prosecution’s failure to issue such a notice and its reliance on

an uncorroborated disclosure statement, which is inadmissible

under Section 25 of the Indian Evidence Act, 1872, unless

strictly compliant with Section 27, underscores the lack of a

prima facie case. The petitioner’s clean record and cooperation

with the investigation further negate the need for custodial

interrogation.
Granting pre-arrest bail is imperative to prevent unjust

deprivation of the petitioner’s liberty. As held in Arnesh Kumar,

mechanical arrests without sufficient evidence violate

fundamental rights and overburden the judicial system. The

petitioner, a law-abiding citizen with no prior criminal history,

faces false implication in a case lacking credible evidence, as

the prosecution’s case hinges on a questionable disclosure

statement. In light of Sushila Aggarwal v. State (NCT)

(2020) 5 SCC 1, which reaffirms the discretionary power to

grant anticipatory bail to prevent misuse of legal processes,

this Hon’ble Court is respectfully urged to grant pre-arrest bail

to safeguard the petitioner’s rights and ensure justice.

The order declining pre-arrest bail to the petitioner is not

only illegal but also unconstitutional, as considering the facts

and the absence of any evidence against the petitioner, he

was entitled to be granted anticipatory bail on the following

grounds:

a) That the petitioner, Manoj Kumar, has been falsely

implicated in FIR No. 11 dated 11.01.2025,

registered under Sections 316(2), 318(4), 319, and

61 of the Bharatiya Nyaya Sanhita, 2023, at Police

Station Sector-17, Faridabad. The allegations in the

FIR are entirely fabricated and baseless, lacking any

credible evidence. Significantly, the petitioner’s

name neither appears in the FIR nor in the charge

 sheet, indicating no direct involvement in the

alleged offense. This establishes that the petitioner

is a victim of malicious prosecution and false

implication.

b) That the prosecution’s case is primarily based on a

disclosure statement of co-accused Sandeep alias

Sanju. However, as per Section 25 of the Indian

Evidence Act, 1872, such statements made to police

officers are inadmissible unless they lead to the

discovery of a material fact as per Section 27. The

Hon’ble Supreme Court in Tofan Singh v. State of

Tamil Nadu [(2021) 4 SCC 1] and the Privy

Council decision in Pulukuri Kottaya v. Emperor

(AIR 1947 PC 67) have clarified this principle. Here,

no recovery or discovery has resulted from the said

statement, rendering it unreliable and insufficient to

deny anticipatory bail. Further, circumstantial

evidence such as call detail records or presence near

the alleged crime scene merely establishes contact

with co-accused, which is legally inadequate to infer

conspiracy or active participation.

c) That the investigation in the present matter has

been substantially completed. No material or

recovery remains to be collected from the petitioner.

He has consistently shown willingness to cooperate

 with the investigating agency. Accordingly, custodial

interrogation is unnecessary and would only result in

unwarranted harassment, violating the petitioner’s

rights.

d) That the in Arnesh Kumar v. State of Bihar

[(2014) 8 SCC 273], the Hon’ble Supreme Court

mandated that police must issue a notice under

Section 35 of the BNSS before arresting an accused

for offenses punishable with imprisonment up to

seven years. Section 318(4) of the BNSS, under

which the petitioner is charged, falls within this

category. The police have failed to comply with this

mandatory procedural safeguard, which vitiates the

arrest and strengthens the petitioner’s entitlement

to anticipatory bail.

e) That no incriminating material or proceeds of the

alleged crime have been recovered from the

petitioner. The accusations against him rest on mere

suspicion and uncorroborated statements, lacking

any concrete or independent evidence. The

petitioner’s alleged receipt of commission is a

baseless assertion unsupported by tangible proof.

f) That the Hon’ble Supreme Court and this Hon’ble

Court have consistently held that anticipatory bail is

 the rule and custodial detention is the exception,

particularly when there is no strong prima facie

case. The judgment in Balraj vs. State of Haryana

(CRMM-49853-2024) underscores that anticipatory

bail must be granted where the accused is falsely

implicated and custodial interrogation is not

warranted. Further, Sushila Aggarwal v. State

(NCT) (2020) 5 SCC 1 reiterates that the legal

process must not be misused to cause unnecessary

harassment.

g) That the petitioner is a permanent resident, has no

history of criminal conduct, and poses no risk of

absconding or tampering with evidence. Granting

anticipatory bail will not impede the investigation or

affect public peace and order in any manner.

h) That the petitioner’s fundamental right to personal

liberty under Article 21 of the Constitution is

paramount. In absence of credible evidence and due

to the procedural lapses, anticipatory bail must be

granted to safeguard the petitioner from arbitrary

arrest and protect his liberty against undue

harassment.

i) That upon examining the facts and circumstances of

the case, it is evident that the essential ingredients

 required to constitute the alleged offence envisaged

under Section 316 (2), 318 (4), 319 (2), 61 (2) of

BNS 2023, (section 338, 336(3), 340 (2) of BNS 2023

added later on) are not made out. There is

insufficient material to establish the necessary

elements that would support the continuation of

proceedings. Therefore, in the absence of a prima

facie case, the allegations do not warrant further

legal action at this stage.

j) That the petitioner’s name surfaced for the first time

in the disclosure statement of co-accused Sandeep

@ Sanju, recorded on 12.03.2025, after his arrest.

Prior to this, several co-accused were arrested, and

none implicated the petitioner. The disclosure

statement merely references a general friendship

with the petitioner, lacking any specific details,

monetary transactions, or concrete evidence linking

him to the alleged offense. Furthermore, the

prosecution alleges the petitioner’s mobile location

was in the vicinity of the crime scene and that he

was in contact with co-accused Rajesh. However,

such circumstantial evidence, absent corroboration,

is insufficient to establish involvement, as held in

State of Maharashtra v. Mohd. Sajid Husain

[(2008) 1 SCC 213].

k) That the prosecution’s reliance on the disclosure

statement is legally untenable under Section 25 of

the Indian Evidence Act, 1872, which bars

confessions made to police officers unless they lead

to the discovery of a new fact under Section 27. As

clarified in Pulukuri Kottaya v. Emperor (AIR

1947 PC 67), only the portion of a disclosure

statement directly leading to a material discovery is

admissible, and such statements must be voluntary

and free from coercion. In Tofan Singh v. State of

Tamil Nadu [(2021) 4 SCC 1], the Hon’ble

Supreme Court extended this prohibition to officers

under special statutes, emphasizing rigorous

scrutiny for voluntariness. In the present case, the

disclosure statement has not led to any recovery or

discovery, lacks corroboration, and its voluntariness

is doubtful, rendering it inadmissible and unreliable.

l) That the offense under Section 318(4) BNS, 2023,

punishable by up to seven years’ imprisonment, falls

within the ambit of Arnesh Kumar v. State of

Bihar [(2014) 8 SCC 273], which mandates that

arrests for such offenses should not be routine.

Section 35 of the Bharatiya Nagarik Suraksha

Sanhita (BNSS), 2023, requires the police to issue a

notice before arrest and justify its necessity. The

 prosecution’s failure to comply with this mandatory

safeguard vitiates any potential arrest,

strengthening the petitioner’s entitlement to

anticipatory bail.

8. That petitioner is ready to join investigation and

cooperate with the Investigating Agency as and when

required.

9. That the petitioner undertakes that in case they have

been given concession of Anticipatory bail by this Hon’ble

Court, petitioner will not misuse the concession of bail

and put appearance before the Ld. Trial Court on each

and every date and will abide by all the conditions as put

by this Hon’ble court.

10. That nothing is to be recovered from the petitioner, hence

the custodial interrogation is not required for the

petitioners and the petitioners deserve the benefit of

Anticipatory Bail.

11. That the main object of the bail is to secure appearance

of the accused person at trial. The object of bail is neither

punitive nor preventative. Principle rule to guide release

on bail should be to secure the presence of the petitioner

who seeks bail, to take judgment and serve sentence in

the event of Court punishing him with imprisonment at

the end of trial.

12. That keeping in view the aforesaid facts and

circumstances, the present petitioners may kindly be

released on Pre-arrest bail, in the interest of justice.

13. That the petitioner undertakes that they will not abscond

and will present themselves before the learned trial court

on each and every date. The petitioner further undertakes

not to leave India without the prior permission of this

Court. The petitioner also undertakes to abide by all the

conditions of bail laid down under section 482 BNSS 2023.

14. That the petitioner has not been declared as Proclaimed

offender by any competent Court of Law.

15. That as per the instructions supplied to the counsel, no

other case/FIR of similar nature or any other case/FIR

under any other act is pending or decided against the

petitioner in any competent Court of Law.

16. That no such or similar petition is pending before the

Court of Sessions or any other Court at the time of filing

of the petition.

17. That no such or similar petition has been filed by the

petitioner in this Hon’ble Court or in the Hon’ble Supreme

Court of India.

It is, therefore, respectfully prayed that the present petition

be allowed and the petitioner may kindly be granted the

concession of anticipatory bail in case FIR No.11, dated

11.01.2025 under Section 316(2), 318(4), 319(2), 61(2) of BNS

2023, (section 338, 336(3), 340(2)of BNS 2023 added lateron)

registered at Police Station sector-17, District Faridabad,

Haryana in the interest of justice.

It is further prayed that during the pendency of the present

petition the arrest of petitioner may be kindly be stayed, in the

interest of justice.

It is further prayed that the petitioner may kindly be

exempted from filing the certified/typed copies of annexures

and the photocopies/true translated copies of the same may

kindly be taken on record, in the interest of justice.

NOTE: AFFIDAVIT IS ATTACHED.

CHANDIGARH
DATED: 26.05.2025

[RAM BHATI] [NARESH K. CHHOKAR]

ADVOCATES
COUNSELS FOR THE PETITIONER

IN THE HIGH COURT FOR THE STATES OF PUNJAB AND

HARYANA AT CHANDIGARH
CRM-M No.__________ of 2025
Manoj kumar …Petitioner

Versus

State of Haryana …Respondent

Manoj Kumar aged about 40 years, S/o Sh. Abhay Singh, R/o
H.No.215, Near Mata Chowk, Chandpur, District Faridabad,
Haryana (Aadhar No.326555038177) (Mob. No.9315990733)

I, the above named deponent, do hereby solemnly affirm

and declare as under:-
1. That the contents of the accompanying petition are true
and correct to the knowledge of the Deponent. No part of
the accompanying petition is false and nothing relevant
has been concealed or misstated therein.
2. That the contents of the petition have been read over to
the deponent and for want of brevity have not been
reproduced in the affidavit.

3. That Aadhar Card is annexed with the petition for identity

and residential proof and for impleading as a party.

4. That no such similar petition is pending before the Court

of Sessions or any other Court at the time of filing of the
petition.

CHANDIGARH
DATED: 26.05.2025 DEPONENT

VERIFICATION:-

Verified that the contents of the above affidavit are true and
correct to my knowledge and no part of it is false. Nothing
material has been concealed.

CHANDIGARH
DATED: 26.05.2025 DEPONENT
 ANNEXURE P-1

FIR No.11, dated 11.01.2025 under Section 316(2),

318(4), 319, 61 of BNS, registered at Police Station

Sector 17, District Faridabad, Haryana.

Sir SHO Police Chowki, Sector 16, Police Station Sector 17,

Faridabad. Subject: Application regarding fraudulently selling

land and grabbing money. Sir, the request is that we are

permanent residents of applicants and associated with the

business of facilitating land purchases for N.S.M. Realtech and

Developers LLP, Lajpat Nagar, New Delhi. Sir, Aziz Khan son of

Shri Hameed Khan, resident of Tikari Yahman, Mobile No.

9813801632 and Nawab Khan, Mobile No. 8090049984 son of

Shri Mansoor Ali, resident of House No. 1147, Street No. 44,

Near Sardar Patel School, Jeevan Nagar, Ballabgarh, Faridabad,

Haryana and Sandeep alias Sanju son of Shri Tarachand

Pandit, resident of village Dhatir, Palwal and Rajesh son of Shri

Ramsharan, resident of village Chhainsa and Srinivas resident

of Tigaon and one woman and others were known to each

other. They came to us with papers of a land which was

situated in Zaidapur, Palwal-Sohna Road, Palwal. They showed

us that land and showed us the papers which were in the name

of Hardei W/O Hari Singh, resident of Badshahpur, Gurugram.

We took the papers of that land to Sachin son of Ashok Kumar,

who is a Partner in N S M Realtech & Developers, LLP, Lajpat

Nagar, Delhi. Presently residing at House No. 1351, Sector 16,

Faridabad, Haryana. Who agreed to buy the land and after that

we contacted Aziz Khan and Nawab Khan, then they brought a

woman and three other persons in a Boleno car registration

number HR 29 AQ 6292 and HR 87 K 0598 to Sachin's

residence house number 1351, Sector 16, Faridabad, Haryana

and introduce them as Mrs. Hardei Devi and her son Bablu

Saini and got us to deal with them and Sachin gave them Rs.

2,00,000/- in cash and RTGS of Rs. 54,00,000/- on 07.01.2025

and cheque of Rs. 44,00,000/- dated 10.01.2025. We deposited

the amount in PNB Bank, Tigaon branch, Faridabad account no.

7405000100080999, which was in the name of Hardei Devi.

After that, when we went to the land, we found out that the

people who owned the land had not sold it at all. Sir, the above

mentioned culprits had prepared the papers through fraud and

forgery and cheated us Rs. 1,00,00,000/- (Rs. 1 crore) from us

has been usurped. Therefore, it is requested to you sir that a

case be filed against the culprits and appropriate legal action

be taken and our money would recovered. Sir, it will highly

appreciated. Applicants - Sanjay alias Dharampal son of Shri

Mahabir Mob. 9416448139 and Krishna son of Shri Balbir

Singh, Mob. No. 9306341136 residents of Gaurela Mohalla,

Sohna Road, Palwal, Haryana.

TRUE TRANSLATION OF RELEVANT EXTRACT

ADVOCATE
 IN THE HIGH COURT FOR THE STATES OF PUNJAB AND
HARYANA AT CHANDIGARH

CRM-M No.__________ of 2025

Manoj Kumar …Petitioner

Versus

State of Haryana …Respondent

INDEX
Sr. Particulars Dated Pages Court
No. Fee
A. Urgent Form 26.03.202 A
5
B. SYNOPSIS B
1. Application for grant 26.03.202 C
of leave 5
2. Affidavit in support D
st
3. 1 Petition U/s 482 26.03.202 1-21
BNSS 5
4. Affidavit in support 26.03.202 22
5
5. Annexure P-1: FIR 11.01.202 23-24
5
6. Annexure P-2: 17.05.202 25-29
Impugned Order 5
7. Power of Attorney 21.05.202 30-31
alongwith Aadhar Card 5
VERNACULARS
8. Annexure P-1: FIR 11.01.202 32-39
5
TOTAL FEES
NOTES:
1. Any Similar Case: No
2. Whether any former/sitting MP/MLAs is involved in the
present case: No

CHANDIGARH
DATED: 26.05.2025

[RAM BHATI] [NARESH K. CHHOKAR]

 PH/1488/2023 P/1125/2011

ADVOCATES
COUNSELS FOR THE PETITIONER

IN THE HIGH COURT FOR THE STATES OF PUNJAB AND

PUNJAB AT CHANDIGARH

SYNOPSIS

 FIR No. 11, dated 11.01.2025, registered under Sections

316(2), 318 (4), 319, and 61 of the Bharatiya Nyaya

Sanhita, 2023, at Police Station SECTOR-17, Faridabad,

Haryana ANNEXURE P-1.

 All the accussed have been arrested who were named in

the FIR.

 The name of the present petitioner has been surfaced in

the disclosure statement of accussed Sandeep @ sanju.

 Present petitioner not named in the FIR nothing to do with

this alleged occurrence and not the beneficiary in any

manner.

 Anticipatory bail decline order of the learned Additional

Sessions Judge vide order dated 17.05.2025 Annexure P-

2.

 Hence the present petition.

CHANDIGARH

DATED: 26.05.2025
[RAM BHATI] [NARESH K. CHHOKAR]

ADVOCATES

COUNSELS FOR THE PETITIONER