In this regular bail application filed under Section 430 of the Bharatiya Nagarik Suraksha Sanhita, 2023 [or corresponding provisions], the petitioner Annu Dhankar sought regular bail in connection with FIR No. 355/2024 registered at Police Station Special Cell for offenses under Sections 302, 120B, 174A, 419, 420, 468, and 34 of the IPC. The applicant was accused of honey-trapping the deceased, leading to his fatal shooting by shooters at a restaurant in Rajouri Garden on June 18, 2024, under instructions from overseas proclaimed offenders. Justice Girish Kathpalia dismissed the bail application, rejecting the sole contention that non-supply of written grounds of arrest at the exact time of detention warranted bail. The Court held that her arrest stemmed from being a proclaimed offender pursuant to due legal process, that no prejudice was caused as she was immediately provided legal assistance and informed through court proceedings, and that her involvement in adopting multiple false identities and evading arrest to flee to Nepal weighed heavily against her.
Background and Applicant’s Plea
- The Allegations: The applicant allegedly honey-trapped the deceased and lured him to a Rajouri Garden restaurant on June 18, 2024, where two shooters opened fire and killed him instantly. The killing was purportedly directed by proclaimed offenders Himanshu and Sahil who are hiding in the USA.
- Flight and Apprehension: After being declared a proclaimed offender, the applicant was apprehended in Lakhimpur, Uttar Pradesh, on October 26, 2024, while attempting to flee to Nepal.
- Core Ground for Bail: The applicant’s counsel argued solely that the Investigating Officer failed to supply written grounds of arrest in the arrest memo specific to the present FIR, rendering her detention illegal.
Court’s Analysis and Findings
- Nature of Arrest (Proclaimed Offender): The Court noted that the applicant was not arrested directly during a routine investigation, but rather because she had been declared a proclaimed offender after proper legal procedures (non-bailable warrants and Section 82 CrPC proceedings). Her arrest memo adequately informed her that she was being detained for being a proclaimed offender, which satisfies legal compliance as discussed in Amar Thapa v. State of NCT of Delhi.
- Absence of Prejudice: Even assuming a technical failure to furnish written grounds, the Court found no prejudice was caused. Upon being produced before the Magistrate on October 26, 2024, she had legal representation, her brother was informed of her arrest, and the detailed remand application was reviewed and allowed in her counsel’s presence.
- Criminal Conduct and Identities: The Court highlighted that the applicant not only orchestrated a honey-trap murder but also adopted multiple false identities while hiding across different parts of the country.
Final Outcome
- Bail Dismissed: Finding no merit in the application, the regular bail petition and its accompanying application were dismissed.



