Wednesday, August 26, 2026

WRITTEN OBJECTION ON BEHALF OF ACCUSED NOS. 2, 3 AND 4 AGAINST THE STATE’S APPLICATION UNDER SECTION 480(5) OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 FOR CANCELLATION OF AD-INTERIM BAIL GRANTED ON 13.03.2025

 

DISTRICT: NORTH 24-PARGANAS

IN THE COURT OF THE LEARNED ADDITIONAL CHIEF JUDICIAL MAGISTRATE

AT BIDHANNAGAR

NORTH 24 PARGANAS

 

G.R. No. 230 of 2025

Arising out of Bidhannagar Women Police Station Case No. 06 of 2025

dated 01.03.2025

Under Sections 385/506/509/120B of the Indian Penal Code, 1860

(with subsequently added Sections 419/420/465/467/468/471/109/118/120 IPC)

 

State of West Bengal

...Prosecution

Versus
Ms. Rina Paladhi & Others

 

...Accused Persons

WRITTEN OBJECTION ON BEHALF OF ACCUSED NOS. 2, 3 AND 4

AGAINST THE STATE’S APPLICATION UNDER SECTION 480(5) OF THE

BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 FOR CANCELLATION OF

AD-INTERIM BAIL GRANTED ON 13.03.2025

 

The accused nos. 2, 3 and 4 above named most respectfully submit this written objection to the application filed by the State seeking cancellation of the ad-interim bail granted to them by this Learned Court on 13.03.2025, and state as follows;

 

1. The application for cancellation is wholly misconceived, unsupported by any post-bail misconduct and liable to be rejected. The State does not allege even a single breach of any bail condition, failure to appear, attempt to abscond, non-cooperation with the investigation, intimidation of any witness, interference with the course of justice, or tampering with any document after the order dated 13.03.2025.

 

2. The only ground urged by the State is that, during the subsequent investigation, Sections 419/420/465/467/468/471/109/118/120 IPC have been added and some of those offences are described as serious. A later alteration or addition of penal sections may require the Court to consider the procedural consequences in accordance with law, but it does not retrospectively convert a lawfully granted bail into misconduct, nor does it automatically satisfy the stringent test for cancellation under Section 480(5) BNSS.

 

3. Cancellation of bail already granted stands on a footing materially different from rejection of bail at the initial stage. The jurisdiction is not appellate or review jurisdiction over the earlier order. Liberty once granted cannot be withdrawn merely upon a re-appreciation of the same accusation or because the prosecution has subsequently adopted a graver legal characterisation of substantially the same factual narrative.

 

4. The FIR was registered on 01.03.2025 under Sections 385/506/509/120B IPC upon allegations arising out of the de facto complainant’s prior employment at the College and School of Nursing, Techno India University, West Bengal, and allegations relating to communications and institutional records dating principally from May 2024.

 

5. On 13.03.2025, accused nos. 2, 3 and 4 voluntarily surrendered before this Learned Court. Upon hearing the parties and perusing the formal FIR, written complaint and the materials then produced, this Learned Court expressly recorded that custodial detention was not necessary and granted each accused ad-interim bail of Rs.1,000/- with one registered surety of the like amount.

 

6. The accused persons accepted the jurisdiction of this Learned Court, furnished bail bonds and have remained available to the process. Their prayer for confirmation of bail has remained before this Learned Court. The State’s present application does not disclose any circumstance showing that the accused have abused the protection granted to them.

 

7. By order dated 30.04.2026, this Learned Court disposed of the de facto complainant’s application dated 13.06.2025 in terms of the direction of the Hon’ble High Court dated 17.04.2026. The order permitted monitoring/further investigation on the question of the appropriate penal provisions and directed the Investigating Officer to proceed as per law. It did not cancel or vary the bail of accused nos. 2, 3 and 4, direct their custody, record their guilt, or find any post-bail misconduct. The matter was fixed on 30.06.2026 for their appearance and hearing of their pending applications.

 

8. The order dated 30.04.2026 records that, by an earlier order dated 31.10.2025, this Learned Court had rejected the applications of the de facto complainant and the prosecution seeking monitoring of the investigation and addition of sections. It further records that the de facto complainant thereafter preferred a criminal revision before the Hon’ble High Court at Calcutta and that, by order dated 17.04.2026, the Hon’ble High Court directed this Learned Court to dispose of the de facto complainant’s application dated 13.06.2025 before proceeding further with the case.

 

9. The order further clarifies that the earlier order dated 31.10.2025 had been passed not on the merits of the de facto complainant’s request, but because accused no. 1 had preferred CRR No. 1793 of 2025 for quashing of the proceeding and had obtained protection against coercive action. Consequently, the application dated 13.06.2025 was taken up on merits pursuant to the High Court’s procedural direction.

 

10. Upon perusing the High Court’s order, the record and the case diary, this Learned Court observed that the aspect concerning the provisions of law, as ventilated by the de facto complainant and the prosecution, did not appear to have been properly investigated and that such omission might prejudice the de facto complainant. On that limited basis, the prayer for monitoring of investigation in relation to the relief sought in the application dated 13.06.2025 was allowed, and the Investigating Officer was directed to proceed with the investigation “as per law”.

 

11. Significantly, the order dated 30.04.2026 is an order governing the manner and scope of investigation. It neither adjudicates the truth of the allegations nor records a prima facie finding that accused nos. 2, 3 and 4 committed the subsequently added offences. The expression that an aspect had not been properly investigated is a direction to investigate; it is not proof of the result of that investigation.

 

 

12. The order also does not record that accused nos. 2, 3 and 4 violated any bail condition or obstructed the investigation. It does not direct their arrest or surrender and does not cancel, suspend or modify the ad-interim bail dated 13.03.2025. On the contrary, it fixes 30.06.2026 for their appearance and for hearing the applications filed by them, except accused no. 1. The continuation of their applications for hearing is inconsistent with the State’s attempt to portray the order itself as an automatic cancellation event.

 

13. The State’s subsequent reliance on the order dated 30.04.2026 must therefore remain confined to its true scope. The order authorised a lawful investigation into possible additional provisions; it did not dispense with the independent statutory test under Section 480(5) BNSS. Any material collected thereafter may be investigated and tested in accordance with law, but cancellation still requires cogent grounds relating to the legality of the bail order or abuse of liberty, neither of which is pleaded.

 

14. The materials now relied upon by the State, including the Indian Nursing Council letter dated 22.07.2022, emails of May 2024 and documents annexed in CRR No. 1793 of 2025, all relate to a period preceding the grant of bail. Their investigation pursuant to the order dated 30.04.2026 cannot convert them into supervening conduct on the part of the accused.

 

15. With reference to paragraph 1 of the State’s application, the registration of the FIR and the broad narration of allegations are matters of record. Save and except what is expressly admitted herein, every allegation, inference and legal conclusion against these accused is denied. The prosecution is put to strict proof of each ingredient of every alleged offence.

 

16. With reference to paragraph 2, it is admitted that accused nos. 2, 3 and 4 surrendered on 13.03.2025 and were granted ad-interim bail. It is submitted that the order was passed judicially after consideration of the FIR, written complaint and available materials, with the specific finding that custodial detention was unnecessary.

 

17. With reference to paragraphs 3(a) to 3(h), the State has reproduced and expanded the de facto complainant’s theory but has not identified the particular allegedly forged document, its maker, date, original source, signature or seal said to be false, the person deceived, or the property actually delivered by reason of deception. The correctness of the added sections is a matter for investigation and, if a police report is filed, for consideration at the appropriate stage; allegations cannot be treated as established facts in a cancellation proceeding.

 

18. In particular, a charge of cheating by personation under Section 419 IPC requires the statutory ingredients of personation; a mere allegation that employment or faculty status was misrepresented does not, without particulars, establish that an accused pretended to be another person. Likewise, whether any particular appointment or relieving document answers the statutory definition of “valuable security”, and whether any permission or approval was “property” delivered because of deception, are mixed questions of fact and law which the State has merely asserted.

 

19. With reference to paragraphs 4 to 8, the alleged conspiracy, abetment and concealment are denied. The omnibus use of Sections 109, 118, 120 and 120B IPC cannot substitute for specific factual particulars showing agreement, intentional aid, knowledge of a criminal design or voluntary concealment. The mere addition of these provisions by the Investigating Officer is neither proof of guilt nor proof that continued liberty would prejudice the investigation.

 

20. With reference to paragraph 9, the Indian Nursing Council letter dated 22.07.2022, even if taken at face value, only records an institutional issue concerning simultaneous working and refusal to extend suitability. It does not, by itself, identify which accused created which false document, nor does it establish the essential mens rea for forgery, personation or cheating. It predates the bail order and supplies no ground of post-bail misuse.

 

21. With reference to paragraphs 10 and 11, exchange or forwarding of emails in May 2024 cannot, without more, establish a criminal conspiracy. As regards accused no. 4, the allegation is essentially that she prepared a report and transmitted declarations in the discharge of an institutional role. No overt act of forgery, extortion, threat or personal gain has been particularised against her. All such communications predate the FIR and were capable of investigation without taking the accused into custody.

 

22. With reference to paragraph 12 and the prayer, seriousness of an accusation is relevant but cannot be the sole basis for cancellation of bail already enjoyed without misuse. The State’s own application records that the originally alleged offences were “not serious in nature” and bases the cancellation prayer exclusively on the subsequently added sections. Such addition, unaccompanied by any allegation of obstruction or breach, does not meet the settled threshold for cancellation.

 

23. In Dolat Ram v. State of Haryana, (1995) 1 SCC 349, the Hon’ble Supreme Court held that very cogent and overwhelming circumstances are necessary for cancellation of bail already granted, and identified interference with the due course of administration of justice, evasion or attempt to evade justice, and abuse of the concession granted as material considerations.

 

24. In Puran v. Rambilas, (2001) 6 SCC 338, the Hon’ble Supreme Court explained that bail may be set aside where the grant itself is perverse, illegal or made by ignoring material of substantial nature; that principle does not authorise routine cancellation merely because the prosecution subsequently advances a more severe formulation of the accusation.

 

25. In Abdul Basit alias Raju v. Mohd. Abdul Kadir Chaudhary, (2014) 10 SCC 754, the Hon’ble Supreme Court reiterated that the court granting bail cannot review its own order and that cancellation requires supervening circumstances or misuse, while a challenge to an unjustified bail order lies before a superior forum.

 

26. In Myakala Dharmarajam v. State of Telangana, (2020) 2 SCC 743, the Hon’ble Supreme Court reaffirmed that cancellation requires cogent and overwhelming circumstances, such as evasion of justice, interference with investigation, intimidation of witnesses, likelihood of absconding or abuse of bail. No such circumstance is pleaded here.

 

27. The above principles have been consistently restated by the Hon’ble Supreme Court, including in Imran v. Mohammed Bhava, (2022) 11 SCC 695: bail once granted ought not to be cancelled in a mechanical manner, and the distinction between an appeal against an unjustified grant and cancellation for subsequent misconduct must be maintained.

 

28. The State does not challenge the order dated 13.03.2025 before a superior court as perverse or illegal. Instead, it invokes Section 480(5) BNSS before the same Learned Court while disclosing no abuse of liberty. The application therefore impermissibly seeks a review of the earlier assessment under the label of cancellation.

 

29. All alleged acts relate to 2022-May 2024 and are documentary or institutional in nature. The FIR followed on 01.03.2025. The accused surrendered on 13.03.2025 and have remained on bail for a substantial period. No fresh offence or untoward incident after release is alleged. The prolonged, unblemished compliance itself weighs strongly against incarceration.

 

30. The evidence described by the State consists principally of letters, emails, institutional records and documents already obtained or obtainable from independent bodies. The State does not identify any document destroyed, altered or withheld after bail, any witness approached by the accused, or any investigative direction disobeyed by them. Custodial detention is therefore neither shown to be necessary nor proportionate.

 

31. The presumption of innocence continues. Cancellation at this stage solely because a penal provision carrying a higher punishment has been added would convert the label of an offence into a substitute for the judicial test and would inflict pre-trial detention without a demonstrated necessity.

 

32. Without prejudice, if this Learned Court considers that the addition of any non-bailable offence calls for a fresh bond, additional condition, appearance before the Investigating Officer, or a formal application concerning the added sections, these accused are ready and willing to comply with every reasonable direction. Such safeguards would fully protect the investigation and constitute a proportionate alternative to cancellation.

 

In the premises aforesaid, it is most respectfully prayed that this Learned Court may graciously be pleased to;

 

(a) reject and/or dismiss the application filed by the State under Section 480(5) BNSS for cancellation of the ad-interim bail granted to accused nos. 2, 3 and 4 on 13.03.2025;

 

(b) confirm and continue the bail of accused nos. 2, 3 and 4 upon the existing terms and conditions;

 

(c) in the alternative and without prejudice, permit the accused persons to furnish fresh or additional bail bonds and/or impose such reasonable conditions as may be necessary in relation to the added penal sections, instead of directing them into custody; and

 

(d) pass such further order or orders as this Learned Court may deem fit and proper in the interest of justice.

 

And for this act of kindness, the accused persons as in duty bound shall ever pray.

 

 

 

 

 

 

Place: Bidhannagar

Accused No. 2

Date: ____/____/2026

Accused No. 3

Accused No. 4

 

 

VERIFICATION

 

We, Debojita Chatterjee Chakraborty, Gopa Paul, & Piyali Biswas, accused no. 2, 3, & 4, in the above-mentioned case, do hereby verify that the statements made in paragraphs 1 to 26 are true to my knowledge and belief, based on the case records and legal advice received, and that I have not suppressed any material fact.

 

Verified at Bidhannagar on this ____ day of ____________, 2026.

 

 

 

 

 

 

 

Deponent / Accused

Identified by me,

 

Advocate

 

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