Punjab & Haryana High Court Declines Ex-DIG IPS Bhullar's Second Bail Plea In CBI Trap Bribery Case
The Punjab and Haryana High Court has declined regular bail to Harcharan Singh Bhullar, a suspended DIG of Ropar Range, Punjab Police, in a CBI case alleging demand of illegal gratification, holding that the absence of recovery from the accused himself is of little consequence where the co-accused is alleged to have accepted the bribe on his behalf. [2026 LiveLaw (PH) 267]Justice Manisha...
The Punjab and Haryana High Court has declined regular bail to Harcharan Singh Bhullar, a suspended DIG of Ropar Range, Punjab Police, in a CBI case alleging demand of illegal gratification, holding that the absence of recovery from the accused himself is of little consequence where the co-accused is alleged to have accepted the bribe on his behalf. [2026 LiveLaw (PH) 267]
Justice Manisha Batra, dismissing the petitioner's second successive petition under Section 483 BNSS, observed:
"The contention that no recovery has been effected from the petitioner cannot be stated to be of much substance since the co-accused right is alleged to have accepted the gratification of an amount of Rs.5 lakhs on behalf of the petitioner."
The Court also held that the apprehension of the petitioner influencing material witnesses — many of whom are police officials, could not be ignored, "keeping in view the position which the petitioner was holding in the hierarchy of Police Department."
The prosecution arose out of FIR dated 16.10.2025 registered under Sections 7 and 7-A of the Prevention of Corruption Act, 1988 read with Section 61(2) of the Bharatiya Nyaya Sanhita, 2023.
According to the CBI, complainant Akash Batta submitted a written complaint on 11.10.2025 alleging that the petitioner, then posted as DIG Ropar Range, had demanded illegal gratification through one Krishanu so that no coercive steps would be taken against the complainant's business in FIR registered at Police Station Sirhind, and to secure favourable treatment.
During discreet verification, conversations between Krishanu and the petitioner were recorded, one of which allegedly revealed the petitioner instructing Krishanu to collect ₹8 lakh from the complainant.
The FIR was registered on 15.10.2025 and a trap laid at Chandigarh on 16.10.2025, in which Krishanu was apprehended while allegedly accepting ₹5 lakh from the complainant as part of the gratification. The petitioner was arrested the same day. The challan report under Section 193 BNSS has since been filed.
Senior Advocate Vijay Kumar Jindal, appearing for the petitioner, submitted that the petitioner was on the verge of superannuation after over three decades of service, had been in custody since 16.10.2025, and was not required for further investigation.
It was inter alia argued that no direct role in the demand was established, that no recovery had been effected at his instance, and that the case rested on unsubstantiated allegations. Counsel pointed out that while disposing of the petitioner's special leave petition against the earlier refusal of bail, the Supreme Court had granted liberty to approach the High Court afresh in the event the trial did not commence within two months and that no witness had been examined so far. Since the petitioner stood suspended from service, there was no possibility of his influencing witnesses.
Opposing the plea, Special Public Prosecutor Akashdeep Singh, with Advocate Ravi Kamal Gupta and counsel for the complainant, submitted that the demand was prima facie established from the recorded conversations, the WhatsApp record and the controlled call conducted during verification. It was argued that the earlier petition had been dismissed on merits and no drastic or substantive change in circumstances had been shown; that the trial had commenced but material witnesses — many of them police officials were yet to be examined.
Restating the settled considerations governing bail, the nature of the accusations and of the evidence, the severity of the potential punishment, the character of the accused, the possibility of securing his presence at trial, the apprehension of witness tampering and the larger public interest, the Court turned to the "seriousness of corruption" offences.
The Court relied on the Supreme Court's observations in Niranjan Hemchandra Sashittal v. State of Maharashtra, (2013) 4 SCC 642, that corruption "mothers disorder, destroys societal will to progress... paralyses the economic health of a country" and has reached monstrous dimensions in the country, and in K.C. Sareen v. CBI, (2001) 6 SCC 584, that unless such tentacles are intercepted, corrupt public servants could paralyse the functioning of public institutions.
It further referred to observations in Dr. Subramanian Swamy v. Director, CBI, (2014) 8 SCC 682, that the "office of public power cannot be the workshop of personal gain" and that the status and position of a public servant does not qualify him for exemption from equal treatment.
On the merits, the Court held that the allegations in the FIR, coupled with the recorded conversations, verification report and trap proceedings, prima facie made out a case of demand of gratification and its collection in part through the co-accused.
The plea of no recovery was rejected, as was the plea of want of jurisdiction: although consent under Section 6 of the DSPE Act had been withdrawn by the Punjab Government by the notification of 06.11.2020, both the petitioner and the co-accused were arrested from Chandigarh and the substantial part of the cause of action had also arisen there. The Court additionally noted that the petitioner had earlier filed a writ petition raising these very issues, which was withdrawn.
Noting that charges stood framed and the trial had commenced, even though no witness had yet been examined and finding no drastic or substantive change in circumstances since dismissal of the earlier petition, the Court held that there existed a reasonable apprehension that the petitioner may attempt to influence or tamper with witnesses or otherwise obstruct the proceedings, and declined to exercise its discretion in his favour.
The petition was accordingly dismissed.
Case Title: Harcharan Singh Bhullar @ H.S. Bhullar v. Central Bureau of Investigation
Appearances: Mr. Vijay Kumar Jindal, Senior Advocate with Mr. Manan Khetarpal, Mr. Yashvirdhan Goyal, Mr. Vijayveer Singh and Mr. Abhishek Shukla, Advocates for the petitioner;
Mr. Ravi Kamal Gupta, Advocate with Mr. Akashdeep Singh, Special Public Prosecutor for the respondent-CBI;
Mr. Gurminder Singh Salana, Advocate for the complainant.