Mranal Sharma vs. State of NCT of Delhi
Background
The applicant sought anticipatory bail in an FIR alleging cheating (Sections 318/316 of the Bharatiya Nyaya Sanhita), after he met the complainant through a WhatsApp concert-ticket resale group, represented himself as coming from a wealthy business family and working at a reputed law firm, gained the complainant's trust, and induced him to transfer money under various pretexts: later allegedly sending a forged bank deposit slip to falsely show he had repaid part of the amount.
Decision Breakdown
The applicant's counsel claimed the dispute had been compromised with a partial payment already made, but the complainant's counsel disputed this, and the Court noted that whether money changed hands is legally irrelevant to a bail decision anyway. More seriously, the investigating officer showed the Court a bank's written confirmation that the deposit slip the applicant had circulated was forged (bearing a fake stamp), and the applicant, despite earlier interim protection from arrest, had still not handed over the original slip for forensic analysis or given clear instructions on whether he would do so; on this basis, the Court found custodial interrogation justified and dismissed the anticipatory bail application.
Lesson Learnt
An accused person's continued refusal to hand over key physical evidence (like an allegedly forged document) for forensic testing, even after being granted temporary protection from arrest, can itself become grounds for a court to deny anticipatory bail.