Anticipatory Bail Courts cannot act as recovery forums for alleged financial liabilities or contractual disputes.

The Petitioner sought anticipatory bail regarding FIR No. 348/2025 registered at PS Karol Bagh under Sections 318(4), 336(3), and 340(2) of the Bharatiya Nyaya Sanhita (BNS).

The complainant alleged that the Petitioner, a former stockist, forged documents on the complainant’s letterhead to fraudulently cancel a bank guarantee of Rs. 1,00,00,000/-

The Petitioner contended that the original bank guarantee was returned to him by the complainant after he returned stock worth Rs. 1.5 crores, negating the motive for forgery.

Interim protection was granted on 17.04.2025 and continued through various transfers of the case.

The State noted the Petitioner's cooperation in the investigation but requested the surrender of his digital devices.

Whether the Petitioner is entitled to anticipatory bail given his cooperation with the investigation and the nature of the dispute.

Whether a bail court should act as a forum for the recovery of alleged outstanding dues in commercial disputes.

The court applied the fundamental principle that bail courts are not forums for the recovery of money.

The primary legal framework involved Sections 318(4) (Cheating), 336(3) (Forgery), and 340(2) (using as genuine a forged document or electronic record) of the Bharatiya Nyaya Sanhita (BNS).

The court also considered the principle that anticipatory bail may be granted when the accused joins investigation and the State's requirements (such as seizure of evidence) can be met through conditions rather than custodial interrogation.

The Court observed that the Petitioner had been joining the investigation regularly.

It rejected the complainant’s opposition regarding market outstandings, noting that the complainant had already initiated arbitration proceedings for recovery, which is the appropriate legal channel.

Regarding the allegation of forgery, the Court found that while the FSL report on the letterhead was pending, the Petitioner’s willingness to surrender his computers and printers for forensic examination mitigated the need for custodial interrogation.

The Court prioritized the fact that the dispute arose from an agreement where the Petitioner had already returned substantial stock, creating a plausible defense against the necessity of arrest.

It directed that in the event of arrest, the Petitioner be released on a personal bond of Rs. 25,000/- with one surety.

The holding was conditioned upon the Petitioner joining the investigation and handing over his computers and printers to the Investigating Officer (IO) as directed in writing.

The Court explicitly held that bail proceedings cannot be used as a recovery mechanism for commercial dues.