The Punjab and Haryana High Court has allowed a woman facing about 120 cheque bounce complaints under Section 138 of the Negotiable Instruments Act to furnish one set of bail and surety bonds for all the remaining cases against her.

The cases are pending in courts at Kaithal, Kurukshetra and Karnal. She says she was only an employee of the accused company, authorised to sign the cheques.

Justice Sanjay Vashisth held that bail conditions must be reasonable and proportionate:

“The principle emerging from the aforesaid judgments is that the conditions imposed while granting bail must be reasonable and proportionate and must not be rendered onerous to such an extent that compliance becomes practically impossible. The requirement of securing the presence of an accused before the Court has to be balanced against the right to personal liberty under Article 21 of the Constitution of India.”

The petitioner is accused in complaints filed against M/s Amira Pure Foods Private Limited. According to the State, about 85 of the roughly 120 complaints are pending in courts within the Kaithal Sessions Division, and the rest are in Kurukshetra and Karnal.

On May 12, 2025, the High Court observed that bail and surety bonds furnished by her in one case could be treated as common bonds for the remaining cases, subject to separate bail orders being passed in each.

 In October 2025, she appeared before a court at Kaithal and, the offence being bailable, was admitted to bail on bonds of Rs. 2 lakh with one surety.

Another court within the Kaithal Sessions Division took note of the High Court's order and of the bonds already furnished. Even so, it directed her to furnish fresh common surety bonds of Rs. 1 crore.

She then sought directions allowing a single common personal bond and surety bond of a reasonable amount for all the complaints.

The State counsel submitted that “it is not feasible for the petitioner that qua each of the bail orders, she can furnish these many numbers of bail bonds/surety bonds etc. It is almost impossible for anyone to arrange these many sureties to earn the benefit of bail orders in all such cases.”

The Court relied on the Supreme Court's decision in Girish Gandhi v. State of Uttar Pradesh (2024 INSC 617). In which, the accused had been granted bail in several cases across four States but could not secure release because he was unable to furnish separate sureties in each case. The Supreme Court had observed, “From time immemorial, the principle has been that the excessive bail is no bail. To grant bail and thereafter to impose excessive and onerous conditions, is to take away with the left hand, What is given with the right.”

The Supreme Court had also noted that in practice the choice of sureties is limited to close relatives or friends, and that this circle narrows further in criminal cases because people tend to keep such proceedings private to protect their reputation. It had permitted one personal bond and two sureties in each State to cover all the cases in that State.

It also referred to Hani Nishad v. State of UP, where a single bond was allowed to cover 31 cases, and to Satender Kumar Antil v. CBI, which held that a condition that is impossible to comply with defeats the very object of release.

“Requiring the petitioner to furnish separate and substantial sureties in each of these cases would impose an onerous burden upon her. The principles laid down by the Hon'ble Supreme Court in Girish Gandhi's case (supra) are, therefore, relevant to the controversy in hand,” it added

The petition was disposed of with the directions that the bail and surety bonds of Rs. 10 lakh furnished by the petitioner shall hold good for all the remaining cases against her before the trial courts at Kaithal, Kurukshetra and Karnal, subject to separate bail orders being passed in each case.

It further added that, under Section 441(4) CrPC / Section 485(4) BNSS, which allow courts to accept affidavits on the sufficiency of sureties, the surety shall file one common affidavit disclosing all relevant particulars and commitments. The trial courts may accept this without requiring a separate affidavit in each case.

The petitioner must still appear before the trial courts as required by law. If she fails to appear in any case, that court may begin proceedings to forfeit the bonds.

Appearances: Mr. P.S. Ahluwalia, Senior Advocate with Mr. H.S. Randhawa, Advocate for the petitioner; Ruchi Sekhri, Additional AG, Haryana.