P&H HC Bails Three in Husband’s Alleged Plot to Kill His Wife, Directs Police to Examine Phone and CCTV Evidence

The three petitioners sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in FIR No. 26 dated 16 February 2025, concerning the murder of Lipsi @ Manvi Mittal.

The FIR was initially lodged by her husband, Anokh Mittal, who was later accused of arranging the murder in conspiracy with Partiksha Anand @ Preeti and alleged contract killers.

The prosecution case named seven accused. By the time of the bail hearing, seven of 29 prosecution witnesses had been examined, including three witnesses described as relatives of the deceased; the State also reported recovery of the accused persons’ mobile phones.

The Court’s review of the State’s status report found that the alleged roles relied substantially on disclosure statements, while the report did not identify evidence obtained from the recovered phones. Twenty-one prosecution witnesses remained to be examined.

The petitions were considered under Section 483 of the BNSS, 2023, corresponding to Section 439 of the Code of Criminal Procedure, which provides the High Court with jurisdiction to grant regular bail.

The Court’s reasoning applied the principle that detention pending trial should not be continued solely on serious but unsupported allegations, particularly where the prosecution material relied on disclosure statements and did not explain the evidentiary results, if any, obtained from recovered electronic devices.

The Court also stated that, in the circumstances of the case and having regard to the conduct and manner of investigation, a Constitutional Court may issue appropriate directions to ensure justice, while clarifying that the Court does not ordinarily direct investigation in a particular direction.

The Court found that, despite the length of the State’s status report, it did not disclose what evidence had been collected from the accused persons’ recovered mobile phones; the case against the petitioners, as presented, appeared to rely substantially on disclosure statements.

Given that 21 witnesses remained to be examined, the Court concluded that continued detention could not be justified on the basis of serious but otherwise bald allegations.

Separately, the Court considered the absence of an account of verification of potentially material electronic evidence—including location data, call detail records and CCTV footage—significant, particularly because Anokh Mittal was admittedly present at the scene with the deceased.

It directed the Commissioner of Police, Ludhiana, to examine whether the relevant electronic evidence had been investigated and, if not, to ensure that it was duly examined and that further or fresh investigation be undertaken if warranted by law.

The Court clarified that its observations were not an expression of opinion on the merits, and directed that the matters be listed on 15 December 2026 for the limited purpose of apprising the Court of action taken.