Punjab-Haryana High Court
Sumit Jangra vs State Of Haryana on 21 April, 2026
CRM-
CRM-M-18235-
18235-2026
1
103
IN THE HIGH COURT OF PUNJAB AND HARYANA AT
CHANDIGARH
CRM- 18235-2026
CRM-M-18235-
Sumit Jangra
....Petitioner
versus
State of Haryana
....Respondent
Date of Decision: April 21,
21, 2026
2026
Date of Uploading: April 21,
21, 2026
CORAM: HON'BLE MR. JUSTICE SUMEET GOEL
Present:
Present Mr. Ajit Singh, Advocate for the petitioner
petitioner.
Mr. Gurmeet Singh, AAG Haryana.
Mr. Ashish Gupta,, Advocate for the complainant.
*****
SUMEET GOEL,
GOEL, J. (Oral)
Present petition has been filed under Section 482 of Bharatiya Nagarik Suraksha Sanhita, 2023 (hereinafter to be referred as 'the BNSS') for grant of pre-arrest/anticipatory arrest/anticipatory bail to the petitioner petitioner, in case bearing FIR No.49 dated 17.02.2026, 17.02 registered for the offences punishable under Sectionss 318(4), 319(2), 336(3), 338, 340(2) and 61(2) of the BNS, 2023, at Police Station Udyog Vihar, Gurugram.
2. The gravamen of allegations against the petitioner is that on 22.01.2026, the complainant, Sanjay Kumar, Authorized Representative and Director of Security of Radisson Hotel, Udyog Vihar, Gurugram, submitted a written complaint alleging financial fraud, criminal misappropriation of hotel MAHAVIR SINGH 2026.04.21 18:10 I attest to the accuracy and authenticity of this order/ judgment CRM-
CRM-M-18235- 18235-2026 2 funds, falsification of accounts, and criminal conspiracy by co-accused Harleen Kaur, a Sales Executive of the hotel, in collusion with Sumit Jangra (petitioner herein), a former employee. It was further alleged that during an internal audit and revenue reconciliation of events held in late 2025 and early 2026, significant discrepancies were detected in guest payments, advances, and billing records. Upon inquiry by the hotel's Income Auditor and Credit Manager, it was revealed that guest advances had been fraudulently adjusted against unrelated departure payments, fake and fabricated invoices were generated and provided to guests, payments were dishonestly routed through PM accounts, and substantial cash collections were misappropriated and never deposited with the hotel.
3. Learned counsel for the petitioner has iterated that bare perusal of the FIR itself shows that allegations leveled against the petitioner are concocted, improbable and devoid of any merit. Learned counsel has further iterated that the petitioner has been falsely implicated into the FIR in question. Learned counsel has submitted that the petitioner had already resigned from the Radisson Hotel, and the alleged transactions were discovered much after his resignation. Learned counsel has argued that the petitioner has been implicated just because of some telephonic conversations with the co-accused, namely, Harleen Kaur and the same does not establish involvement of the petitioner in the alleged offence. Learned counsel has submitted that financial fraud and misappropriation of accounts is alleged against the said co-accused - Harleen Kaur. Learned counsel has argued that the petitioner has nothing to do with the offence in question. Learned counsel has submitted that alleged transactions, as mentioned in the bank statement of MAHAVIR SINGH 2026.04.21 18:10 I attest to the accuracy and authenticity of this order/ judgment CRM-
CRM-M-18235- 18235-2026 3 the petitioner, between him and the co-accused pertain to personal transactions relating to day to day expenses since they were sharing a rented accommodation at Gurugram. Learned counsel has submitted that the petitioner joined the preliminary inquiry before the Investigating Officer and fully cooperated therein; thus, there is no apprehension of the petitioner absconding or interfering with the prosecution evidence. 3.1. Learned counsel asserts that the police have not conducted a fair and impartial investigation and the inquiry conducted so far is not only incomplete but also tainted with bias. Moreover, the custodial interrogation should not be used as a punitive measure and is justified only when absolutely necessary for the recovery of material evidence. Learned counsel has argued that nothing is to be recovered from the petitioner. Furthermore, the petitioner is ready to join the investigation and hence no useful purpose would be served by sending him behind the bars. On the aforesaid submissions, the grant of anticipatory bail is entreated for.
4. Per contra, learned State counsel, while referring to the status report by way of an affidavit dated 13/15.04.2026, which is already on record, has opposed the grant of anticipatory bail to the petitioner by arguing that the offence committed by the petitioner is serious in nature. Relevant of the said status report reads thus:
"9. ROLE OF THE PETITIONER:
PETITIONER That in so far as the role of the petitioner is concerned, it is submitted that the petitioner had played an active role in the commission of the present crime. Upon investigation, it was found-out that he acted in active connivance and pursuant to a pre-planned criminal conspiracy with co-accused Harleen Kaur. It is evident that the petitioner facilitated the fraudulent scheme by visiting hotel guests and collecting cash payments on behalf of the hotel, which were never deposited in official accounts, and further impersonated himself as the hotel accountant to address and suppress guest complaints. He knowingly assisted in the generation and circulation of fake receipts and invoices, thereby aiding in the concealment of the misappropriation of funds. His continuous coordination with the co-MAHAVIR SINGH 2026.04.21 18:10 I attest to the accuracy and
authenticity of this order/ judgment CRM-
CRM-M-18235- 18235-2026 4 accused and active participation in unauthorized handling of guest payments and diversion of hotel revenue clearly establish his deliberate, conscious, and integral role in the systematic execution of financial fraud, resulting in substantial wrongful loss to the complainant establishment."
4.1. Learned State counsel has also iterated that the allegations against the petitioner are specific and direct. Given the severity of the offence regarding dishonestly cheating, there exists a substantial likelihood that the petitioner may abscond or tamper with the evidence, if he is enlarged on bail. On the strength of these submissions, dismissal of the petition in hand is entreated for.
4.2. Learned counsel for the complainant, while raising submissions in tandem with the submissions of learned State counsel, has also vehemently opposed the grant of anticipatory bail to the petitioner by arguing that the allegations leveled against the petitioner are serious in nature. Learned counsel has submitted that the petitioner along with his co-accused has played financial fraud, resulting in substantial wrongful loss to the complainant. Learned counsel has submitted that, in case, the petitioner is granted the concession of anticipatory bail, there is all likelihood that the petitioner may abscond from the process of justice as also interfere/ intimidate the prosecution witnesses/ evidence. On the strength of these submissions, dismissal of the petition in hand is entreated for.
5. I have heard the learned counsel for the rival parties and have gone through the available record of the case.
6. As per the case put forth in the FIR in question, the allegations against the petitioner are serious in nature. As per the prosecution case and upon perusal of the status report dated 13/15.04.2026, as well as the order dated 25.03.2026 passed by the Court below declining anticipatory bail to the MAHAVIR SINGH 2026.04.21 18:10 I attest to the accuracy and authenticity of this order/ judgment CRM-
CRM-M-18235- 18235-2026 5 petitioner, it emerges that during the course of investigation, co-accused Harleen Kaur was acting in active connivance and criminal conspiracy with the petitioner, who had earlier been employed at the same hotel and had left his job approximately one year prior to the incident. It was revealed that whenever guests approached the hotel for booking rooms or banquet halls for weddings or parties, co-accused - Harleen Kaur, in her capacity as Sales Executive, dealt with them. In cases where payments were made online, the amounts were duly deposited with the accounts department and recorded in the ledger. However, when payments were made in cash, Harleen Kaur allegedly retained the cash and issued fake receipts to the guests. It further emerged that she provided the mobile number 9319968268 to guests via email, and the petitioner would visit the guests to collect cash. In case of any complaints, the petitioner would contact the guests from the said number, impersonating himself as the hotel accountant, and address their concerns. At the time of events, Harleen Kaur would manipulate the ledger by adjusting payments of one guest against another to ensure that events proceeded smoothly and the fraud remained undetected. In this manner, both accused, in collusion with each other, dishonestly collected booking amounts from hotel guests, misappropriated the funds, and caused wrongful loss to the complainant hotel amounting to several lakhs of rupees. 6.1. In view of the material on record, the petitioner appears to have played an active and key role in a well-planned conspiracy with co-accused Harleen Kaur in committing financial fraud and misappropriation of hotel funds. The allegations, prima facie, reveal a systematic modus operandi involving collection of cash from guests, issuance of fake receipts, MAHAVIR SINGH 2026.04.21 18:10 I attest to the accuracy and authenticity of this order/ judgment CRM-
CRM-M-18235- 18235-2026 6 impersonation as a hotel official, and manipulation of accounts to conceal the fraud, thereby causing substantial wrongful loss to the complainant hotel.
7. The petitioner has been specifically named in the FIR. No cause nay plausible cause has been shown, at this stage, from which it can be deciphered that the petitioner has been falsely implicated into the present FIR.
8. It is befitting to mention here that while considering a plea for grant of anticipatory bail, the Court has to equilibrate between safeguarding individual rights and protecting societal interest(s). The Court ought to reckon with the magnitude and nature of the offence; the role attributed to the accused; the need for fair and free investigation as also the deeper and wide impact of such alleged iniquities on the society. It is imperative that every person in the Society can expect an atmosphere free from foreboding & fear of any transgression. At this stage, there is no material on record to hold that prima facie case is not made out against the petitioner. The material which has come on record and preliminary investigation, appear to be established a reasonable basis for the accusations. Thus, it is not appropriate to grant anticipatory bail to the petitioner, as it would necessarily cause impediment in Sharma,, (1997) 7 SCC 187 : 1997 effective investigation. In State v. Anil Sharma SCC (Cri) 1039], the Supreme Court held as under : (SCC p. 189, para 6) "6. We find force in the submission of CBI that custodial interrogation is qualitatively more elicitation-oriented than questioning a suspect who is well-ensconced with a favourable order under Section 438 of the Code. In a case like this, effective interrogation of a suspected person is of tremendous advantage in disinterring many useful informations and also materials which would have been concealed. Success in such interrogation would elude if the suspected person knows that he is well protected and insulated by a pre-arrest bail order during the time he is interrogated. Very often interrogation in such a condition would reduce to a mere ritual. The argument that the custodial interrogation is fraught with the danger of the person being subjected to third-degree methods need not be countenanced, for, such an argument can be advanced by all accused in all criminal cases. The Court has to presume that responsible police officers would conduct MAHAVIR SINGH 2026.04.21 18:10 I attest to the accuracy and authenticity of this order/ judgment CRM-
CRM-M-18235- 18235-2026 7 themselves in a responsible manner and that those entrusted with the task of disinterring offences would not conduct themselves as offenders."
9. In view of the seriousness of the allegations, this Court finds no compelling ground to extend the benefit of discretionary relief to the petitioner. Moreover, custodial interrogation of the petitioner is necessary for an effective investigation & to unravel the truth. The petition is, thus, devoid of merits and is hereby dismissed.
dismissed
10. Nothing said hereinabove shall be deemed to be an expression of opinion upon merits of the case/investigation.
11. Pending application(s), if any, shall also stand disposed off.
(SUMEET GOEL) JUDGE April 21, 21, 2026 mahavir Whether speaking/reasoned: Yes/No Whether reportable: Yes/No MAHAVIR SINGH 2026.04.21 18:10 I attest to the accuracy and authenticity of this order/ judgment