Punjab-Haryana High Court
Vikas Bishnoi vs State Of Haryana on 23 April, 2026
CRM-M-55881-2025 -1-
IN THE HIGH COURT OF PUNJAB & HARYANA
AT CHANDIGARH
110 CRM-M-55881-2025
Date of decision: 23rd April, 2026
Vikas Bishnoi
...Petitioner
Versus
State of Haryana
...Respondent
CORAM: HON'BLE MRS. JUSTICE MANISHA BATRA
Present: Mr. Angrej Singh, Advocate,
Mr. Madan Sandhu, Advocate and
Mr. Parveen, Advocate for the petitioner.
Mr. Neeraj Poswal, Assistant Advocate General, Haryana.
Mr. Jagat Vir, Advocate with
Mr. Rehatbir Singh Mann, Advocate for the complainant.
***
MANISHA BATRA, J (ORAL):-
The instant one is the second petition filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (for short 'BNSS') by the petitioner seeking grant of regular bail in case bearing FIR No. 249 dated 05.09.2023 registered under Sections 419, 420, 465, 467, 468, 471 and 120-B of IPC at Police Station Sector 14, Gurugram. His previous petition bearing CRM-M- No. 12942-2025 had been dismissed vide order dated 29.04.2025.
2. The aforementioned FIR was registered on the allegations that Sh. Sunil Kumar father of the complainant Dharamvir, was the allottee of a PARVEEN SHARMA 2026.04.23 19:33 I attest to the accuracy and integrity of this document CRM-M-55881-2025 -2- plot situated at Sector 23-23-A, Gurugram. He had died way back in the year 2010. The petitioner by hatching a conspiracy with his father Krishan Lal and co-accused Kirta Ram, portrayed accused Kirta Ram as the father of the complainant and by impersonating him and by getting false and forged documents prepared, executed a deed of conveyance of the plot owned by the father of the complainant in favour of two persons namely Nisha Singh and Rampal Singh Tomar. Accused Krishan Lal and Sudesh Kumar were attesting witnesses to the said conveyance deed. The petitioner identified Kirta Ram who portrayed himself as Sunil Kumar in affidavits and indemnity bonds etc. filed before the Estate Officer Huda, Gurugram thereby cheating the complainant. The petitioner was arrested on 04.04.2024 and presently, he is facing trial for commission of the aforementioned offences. The previous petition as filed by him had been dismissed by making the following observations:-
"7. The petitioner by hatching a conspiracy with the co-accused is alleged to have got registered conveyance deed qua the property owned by the father of the complainant and sold the same to some other persons by impersonating the deceased father of the complainant and by preparing false and fake documents. He apparently appears to be the mastermind of the crime as well as the main beneficiary of the transaction. The allegations against him are quite serious in nature. He has criminal antecedents and some other cases showing commission of similar offences have been registered against him. There is nothing on record to infer that there would be any undue delay in conclusion of the trial. Taking into consideration the nature of the allegations as levelled against the petitioner, the part attributed to him, the quantum of sentence which the conviction may entail and the attendant facts and PARVEEN SHARMA 2026.04.23 19:33 I attest to the accuracy and integrity of this document CRM-M-55881-2025 -3- circumstances but without meaning to make any comment on the merits of the case, this Court is of the considered opinion that the petitioner does not deserve to be extended benefit of bail at this stage. Accordingly, the petition is dismissed."
3. The petitioner filed a Special leave to Appeal (Criminal) No. 8046 of 2025 before the Hon'ble Supreme Court against the order dated 29.04.2025 but the same had been dismissed as withdrawn.
4. It is argued by learned counsel for the petitioner that after dismissal of his previous petition by this Court, there has been no progress in the trial as no prosecution witness has been examined so far. An application for alteration of charge has been moved which is lying pending before the trial Court. There are no chances of conclusion of trial in near future. The subject offences are triable by Magistrate. Each day spent by the petitioner in custody has furnished a ground afresh to him to seek concession of bail. His continued detention is not going to serve any fruitful purpose. It is, therefore, urged that he deserves to be released on bail.
5. Per contra, learned State counsel assisted by learned counsel for the complainant has vehemently argued that there are serious allegations against the petitioner. The special leave petition as filed by the petitioner against the previous orders passed by this Court, had been dismissed by the Hon'ble Supreme Court. Even the prayer made by the co-accused Krishan Lal Bishnoi, who is father of the petitioner, for grant of regular bail in a special leave petition as filed before the Hon'ble Supreme Court has been declined recently vide order dated 09.04.2026. The allegations against the petitioner PARVEEN SHARMA 2026.04.23 19:33 I attest to the accuracy and integrity of this document CRM-M-55881-2025 -4- are serious in nature which involve commission of aforementioned offences including offence punishable under Section 467 of IPC which is punishable up to imprisonment for life. There are chances of petitioner's committing similar offences or absconding, if extended benefit of bail. It is, therefore, argued that the petition does not deserve to be allowed.
6. This Court has heard the rival submissions made by learned counsel for the parties at considerable length.
7. The previous petition as filed by the petitioner had been dismissed by passing a detailed order. The Special leave to appeal as filed by the petitioner against that order had been dismissed as withdrawn. The petitioner was the master mind behind the subject offences and has also been the main beneficiary of the transactions. The allegations against him are serious in nature. One of the offences for which he has been challaned is punishable upto life imprisonment. No doubt, a successive petition for grant of regular bail is maintainable, however, for such a petition to succeed, the petitioner is required to show some substantial and drastic change in the circumstances. No such drastic change is however, pointed out in this case except the prolonged incarceration. The well settled proposition of law is that in cases of serious offences, prolonged incarceration cannot be considered to be the only reason for grant of bail. Taking into consideration the above discussed facts, this Court is of the considered opinion that the petition does not deserve to be allowed. Accordingly, the same is dismissed.
8. It is clarified that observations made hereinabove shall not be PARVEEN SHARMA 2026.04.23 19:33 I attest to the accuracy and integrity of this document CRM-M-55881-2025 -5- construed as an expression of opinion on the merits of the case.
9. Since the main petition has already been disposed of, pending application, if any, is rendered infructuous.
[MANISHA BATRA] JUDGE 23rd April, 2026 Parveen Sharma
1. Whether speaking/ reasoned : Yes / No
2. Whether reportable : Yes / No PARVEEN SHARMA 2026.04.23 19:33 I attest to the accuracy and integrity of this document