Important Judgments of Punjab and Haryana High Court (2025) - Legal Bites Year Update

A compact overview of the key decisions delivered by the Punjab and Haryana High Court in 2025, illustrating the Court’s approach to criminal procedure, constitutional rights, and public interest. The rulings reaffirm restrictions on a Magistrate’s powers, reject the private settlement of serious cyber and economic offences, uphold stringent standards in judicial recruitment and bail, and protect individual rights in personal and administrative matters, collectively reflecting a strong and consistent adherence to the rule of law.

Important Judgments of Punjab and Haryana High Court (2025)
Legal Bites Year Update

1) Magistrate Has No Power to Direct Re-Investigation

The Punjab and Haryana High Court, in Gurmeet Singh v. State of Haryana (2025), held that a Magistrate has no jurisdiction to direct re-investigation or de novo investigation once a police report is filed under Section 173(2) CrPC, now Section 193(3) BNSS. Reiterating settled law, the Court clarified that a Magistrate’s powers are confined to permitting or directing further investigation under Section 173(8) CrPC, Section 193(8) BNSS, which is supplementary in nature and does not wipe out the earlier probe.

The authority to order a fresh or re-investigation, meant for rare cases of tainted or unfair investigation, vests exclusively with the constitutional courts. Upholding the validity of a supplementary charge-sheet filed after further investigation, the Court also rejected objections based on self-incrimination, noting that Article 20(3) protection applies only after a person is formally accused.

2) Cyber Fraud Not a Private Dispute: Compromise Cannot Justify FIR Quashing

The Punjab and Haryana High Court, in Badri Mandal & Ors. v. State of Haryana & Anr. (2025), refused to quash an FIR alleging cyber fraud despite a compromise between the complainant and the accused. The Court held that cyber fraud is not a purely private or personal dispute but a public wrong that undermines trust in digital banking and financial systems. Even though the complainant had received monetary restitution and voluntarily entered into a settlement, the Court ruled that such a compromise cannot neutralise the broader societal and systemic harm caused by digital fraud.

Emphasising settled Supreme Court jurisprudence, the High Court reiterated that offences affecting public interest, economic stability, or digital infrastructure ordinarily fall outside the scope of quashing under Section 528 BNSS merely based on settlement, and accordingly dismissed the quashing petition.

3) 50% Minimum Marks Rule for District Judiciary

The Punjab and Haryana High Court, in Rajesh Gupta v. Punjab and Haryana High Court and Others (2025), dismissed a writ petition challenging the prescription of minimum qualifying marks for appointment as Additional District and Sessions Judge under the Haryana Superior Judicial Service. The Division Bench held that Clause 15 of the recruitment advertisement mandating 50% aggregate marks (45% for reserved categories) was lawful and reasonable, noting that the 2007 Rules were silent on minimum cut-offs and the High Court was competent to supplement them through administrative instructions.

4) Second Bail Plea in SFIO Scam Case Rejected Despite Prolonged Custody

The Punjab and Haryana High Court, in Rajeev Kumar Rana v. Serious Fraud Investigation Office (2025), dismissed a second successive petition for regular bail filed by an accused in the Adarsh Group–ACCSL scam, holding that mere prolonged incarceration of over three years does not constitute a substantial change in circumstances when an earlier bail rejection has been upheld by the Supreme Court.

The Court reiterated the stringent twin conditions under Section 212(6) of the Companies Act, 2013 for offences under Section 447, emphasised that economic offences involving large-scale public funds require a stricter approach to bail, and found no material to dislodge the earlier findings. While declining bail, the Court directed the trial court to expedite the proceedings, clarifying that observations made would not prejudice the merits of the trial.

5) Right to Health Includes Right to Read One’s Medical Prescription

The Punjab and Haryana High Court, in XXXXX v. State of Haryana & Anr. (2025), granted anticipatory bail to the petitioner accused of cheating, forgery, criminal intimidation and rape, noting that he had joined and cooperated with the investigation for over a year and that objections regarding alleged fake documents were matters to be examined at trial. While making the interim protection absolute, the Court observed that any payments allegedly made to secure a government job were themselves for an illegal purpose and that the delayed medical examination weakened reliance on the MLR.

Importantly, the Court took suo motu cognizance of the widespread problem of illegible medical prescriptions and medico-legal reports, holding that the right to receive legible prescriptions forms part of the right to health under Article 21, and issued directions requiring prescriptions to be written in clear capital letters or typed, with States initiating compliance measures.

6) Inadvertent Error in Spouse Column Can’t Lead to Passport Revocation

The Punjab and Haryana High Court, in Navpreet Kaur v. Union of India & Ors. (2025), held that inadvertent mention of a former husband’s name in a passport application after divorce does not amount to suppression of material information justifying revocation under Section 10(3)(b) of the Passports Act, 1967. Observing that marital status is not a statutory ground for refusal of a passport and that such lapses are treated as minor under the Passport Rules, the Court quashed the revocation and appellate orders and directed issuance of a fresh passport with correct particulars within three weeks.

7) Failed Relationship Cannot Be Criminalised as Rape

The Punjab and Haryana High Court, in Himank v. State of Haryana & Anr. (2025), quashed an FIR under Section 376(2)(n) IPC/64(m) BNS, holding that a long-standing consensual relationship which later failed to culminate in marriage cannot be treated as rape on the ground of a false promise to marry.

The Court observed that the parties were mature adults, marriage talks had taken place between their families, a roka ceremony had been performed, and the wedding date had been fixed, indicating bona fide intent rather than deception from the outset. Reiterating settled Supreme Court law, the Court held that unless it is shown that the promise of marriage was false from the very beginning and made solely to obtain sexual consent, criminal prosecution would amount to abuse of process. Accordingly, it quashed the FIR and all consequential proceedings.

8) Habitual Offender Not Entitled to Anticipatory Bail in Cow Slaughter Case

The Punjab and Haryana High Court, in Aasif v. State of Haryana (2025), refused anticipatory bail to the petitioner accused under the Haryana Gauvansh Sanrakshan and Gausamvardhan Act, 2015 and the Prevention of Cruelty to Animals Act, 1960, noting that he was a habitual offender with prior involvement in similar offences. The Court held that anticipatory bail is not meant to provide immunity to repeat offenders, particularly where allegations involve transportation of cows in inhumane conditions with tools suggesting slaughter, and where custodial interrogation is necessary for a fair and effective investigation.