P&H HC Denies Anticipatory Bail To Man Accused Of Rs 25 Lakh UK Visa Fraud, Citing Unrecovered Passport And Alleged Forgery Laptop

The petitioner sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), in FIR No. 147 dated 25 May 2026, registered under Sections 318(4), 336(2), 336(3), 340(2), 351(2) and 61(2) of the Bharatiya Nyaya Sanhita, 2023 (BNS).

The prosecution alleged that the petitioner and co-accused induced the complainant to pay ₹25 lakh for a UK skilled-worker visa, took possession of his passport and educational certificates, and used forged visa-related documents.

The petitioner alleged false implication, delay in registration of the FIR, absence of payment to him, and a connection between the present complaint and an earlier case; he also offered to join the investigation.

The State opposed bail, asserting that the petitioner received ₹12 lakh, prepared forged documents, and concealed electronic equipment that remained to be recovered.

The Sessions Court had declined anticipatory bail; the High Court dismissed the present petition.

Section 482 BNSS empowers the Court to grant anticipatory bail.

In deciding whether to exercise that discretion, the Court considered the nature and gravity of the alleged offence, the accused’s attributed role, the need for a free and fair investigation, and the wider impact of the alleged conduct on society.

The Court relied on State v. Anil Sharma, (1997) 7 SCC 187, which recognises that custodial interrogation may be more effective than questioning a suspect protected by pre-arrest bail, particularly where relevant information or material may otherwise remain concealed.

The alleged offences were charged under Sections 318(4), 336(2), 336(3), 340(2), 351(2) and 61(2) BNS.

The Court treated the allegations as specific and supported, at the preliminary stage, by the complainant’s account, the State’s reply, and the investigation material.

It noted that the complainant’s original documents, the alleged money, and evidence relating to the forged documents and electronic devices remained to be recovered.

The petitioner’s claims of delay, false implication, and prior animosity raised disputed factual matters that the Court considered unsuitable for determination at the anticipatory-bail stage; the State’s inquiry also denied the asserted relationship between the two complainants.

Having regard to the alleged role, criminal antecedents disclosed in the petition, and outstanding investigative steps, the Court concluded that custodial interrogation was necessary and that pre-arrest bail could impede effective investigation.

The petition was dismissed; the Court clarified that its observations were not an opinion on the merits of the case or investigation, and disposed of any pending applications.