Lehna Singh and another v. State of Punjab and another, 2026

The petitioners were accused in an FIR registered at Kapurthala, Punjab, alleging cheating and immigration fraud.

The prosecution alleged that the petitioners collected ₹35 lakh from the complainant on the promise of facilitating his son's immigration to the United States.

According to the allegations, the petitioners neither fulfilled the promise nor returned the money.

The petitioners earlier sought anticipatory bail before the Punjab & Haryana High Court.

The High Court dismissed the anticipatory bail applications by reasoned orders dated 24 February 2026 and 21 April 2026.

Petitioner No. 2 challenged the High Court's order before the Supreme Court.

The Supreme Court declined to interfere with the rejection of anticipatory bail but granted liberty to the petitioner to surrender within two weeks and apply for regular bail, directing that such application be considered on its own merits.

Instead of surrendering, the petitioner again approached the High Court by filing a second anticipatory bail petition.

The petitioners relied upon an alleged compromise dated 30 May 2026 with the complainant as a fresh ground for seeking anticipatory bail.

The High Court dismissed the second anticipatory bail petition as not maintainable.

The Court held that once anticipatory bail had been rejected by the High Court and the Supreme Court had declined interference, the issue attained finality.

The Court observed that the petitioner was bound to comply with the Supreme Court's direction to surrender and seek regular bail.

The Court held that the alleged compromise dated 30 May 2026 did not constitute a fresh circumstance justifying reconsideration of anticipatory bail.

The Court observed that a compromise between the parties cannot override or dilute the binding directions issued by the Supreme Court.

The Court held that the petitioner's conduct in avoiding compliance with the Supreme Court's order disentitled him from the discretionary relief of anticipatory bail.

The Court clarified that its observations were confined to the bail proceedings and would not prejudice the merits of the criminal trial or investigation.

The judgment reinforces the principle of finality of judicial orders by preventing repeated anticipatory bail petitions on substantially identical grounds.

The Court emphasized that litigants cannot circumvent binding directions of the Supreme Court by filing successive applications before subordinate courts.

The decision highlights that a subsequent compromise does not automatically create a new ground for anticipatory bail, particularly where the Supreme Court has already prescribed the appropriate legal course.

The judgment underscores the importance of judicial discipline and adherence to the hierarchy of courts.

The Court reaffirmed that anticipatory bail is an equitable and discretionary remedy, and the conduct of the applicant is a relevant consideration.

By refusing relief, the Court discouraged abuse of the judicial process through repeated litigation after unsuccessful attempts before higher courts.

The decision serves as a precedent that only substantial and legally significant changes in circumstances can justify entertaining a successive anticipatory bail application.

The judgment balances the rights of the accused with the need to preserve the authority of judicial orders and ensure procedural fairness.