ANNU DHANKAR Vs STATE (NCT OF DELHI)

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IN THE HIGH COURT OF DELHI AT NEW DELHI

Date of Decision: 19.08.2026

CNR No. DLHC010385312026

BAIL APPLN. 3410/2026 & CRL.M.A. 25446/2026

ANNU DHANKAR

.....Petitioner

Through: Mr. M. S. Khan, Advocate (through

videoconferencing).

versus

STATE (NCT OF DELHI) .....Respondent

Through: Mr. Sanjeev Sabharwal, APP for State

with Inspector Satbir Singh and SI

Parhalad, PS Special Cell/SWR.

CORAM: JUSTICE GIRISH KATHPALIA

J U D G M E N T (ORAL)

The accused/applicant seeks regular bail in case FIR No. 355/2024 of

PS Special Cell for offence under Section 302/120B/174A/419/420/468/34

IPC.

Learned APP for State assisted by Investigating Officer/Inspector

Satbir Singh accepts notice and strongly opposes the bail application.

Broadly speaking, the allegation against the accused/applicant is as

BAIL APPLN. 3410/2026

Page 1 of 4 pages follows. The accused/applicant honey-trapped the deceased and called him

to a restaurant in Rajouri Garden on 18.06.2024, where the shooters namely

Ashish and Vikas fired multiple rounds of bullets, causing instant death of

the deceased. The shooters Ashish and Vikas were killed later in an

encounter, as informed by the IO/Inspector Satbir Singh. The killing of the

deceased in the present case was done on instructions of accused Himanshu

and Sahil, both of whom are proclaimed offenders, now hiding somewhere

in the USA. The present accused/applicant also was declared as a

proclaimed offender, after which she was apprehended from Lakhimpur, UP

on 26.10.2024 when she was trying to flee away to Nepal.

On behalf of accused/applicant, it is submitted that the only ground

being raised in this application is the failure of the IO to supply grounds of

arrest to the accused/applicant. It is submitted by learned counsel for

accused/applicant that there were two arrest memos pertaining to the

accused/applicant, one of which was on the basis of DD No. 4A while the

other one was on the basis of the present case. In the arrest memo related to

the present case also, the grounds of arrest were not mentioned, so the

accused/applicant deserves to be released on bail.

Learned APP for State places reliance on the judgment of this Court

in the case of Amar Thapa vs. State of NCT of Delhi, 2026:DHC:5520,

contending that the legal position as described in the said case remains

unsettled till date. It is submitted by learned APP that the accused/applicant

BAIL APPLN. 3410/2026

Page 2 of 4 pages was arrested on 25.10.2024 in DD No. 4A whereas the impact of non-supply

of written grounds of arrest was elucidated with clarity in the case of Mihir

Rajesh Shah vs. State of Maharashtra & Anr., 2025:INSC:1288, much

later on 06.11.2025. Further, it is also argued by learned APP that no

prejudice was caused to the accused/applicant on account of the alleged nonsupply of grounds of arrest.

To recapitulate, in the present case, the accused/applicant was arrested

on 25.10.2024 on the basis of DD No. 4A as she had been declared a

proclaimed offender. The accused/applicant had been declared proclaimed

offender after applying the procedure established by law, wherein initially

non-bailable warrants were issued, but since the same could not be executed,

proclamation proceedings under Section 82 CrPC were carried out by the

court of competent jurisdiction. It was not a case of direct arrest of the

accused/applicant in the course of investigation. The arrest memo clearly

informed the accused/applicant that she was being arrested because she had

been declared a proclaimed offender and that intimation, in view of legal

position discussed in Amar Thapa (supra) is adequate compliance.

As mentioned above, no prejudice has been shown to have been

caused to the accused/applicant, even if it is assumed to be a case of failure

to furnish grounds of arrest. Admittedly, on the very first occasion after her

arrest, when the accused/applicant was brought before the concerned court,

she was equipped with legal assistance and in the first order dated

BAIL APPLN. 3410/2026

26.10.2024, the learned Magistrate specifically recorded that the information

of arrest had been supplied to also brother of the accused/applicant; and

even the application of the IO for formal interrogation and arrest which

mentioned in detail the circumstances, was allowed by the learned

Magistrate by that order in presence of counsel for the accused/applicant.

Besides the aforesaid, it would also be significant to keep in mind that

the accused/applicant not just honey-trapped the deceased in the present

case, she also has adopted multiple false identities while residing at different

places across the country, as enumerated in order dated 05.06.2026 passed

by the learned Court of Sessions while dismissing her bail application.

Considering the above factors, I do not find it a fit case to release the

accused/applicant on bail. The bail application and the accompanying

application are dismissed.

Copy of this order be sent to the concerned Jail Superintendent for

being conveyed to the accused/applicant immediately.

GIRISH KATHPALIA

Digitally signed by GRISH KATHPALIA

DN: C=N, H=O-HIGH COURT OF DELHI,

f.3.24.0-814048892a77b726fffffe4afc4556

Court OF DELHI.CID: 7047638

postCode=110003, st-Delhi,

serialNumber=d87698164e1c4c057b155709

d8769804b2cee004e2640728901f8e2a6,

cn=GRISH KATHPALIA

Date: 2026.08.19 17:07:21 +0530'

**AUGUST 19, 2026/**dr

BAIL APPLN. 3410/2026

GIRISH KATHPALIA

(JUDGE)

Page 4 of 4 pages