Mandeep Singh Alias Peeta v. State (Nct of Delhi)

O R D E R %

21.08.2026

¶1This application has been filed under Section 483 read with Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023 ('BNSS') seeking regular bail in connection with FIR No. 340/2025, registered at PS Crime Branch, North Delhi, for the offences punishable under Section 25 of the Arms Act, 1959 and Section 25(8) of the Arms (Amendment) Act, 2019.

¶2As per the allegations in the FIR, based on a secret tip received on

19.11.2025, regarding an interstate illegal arms delivery in Rohini, Delhi, a Crime Branch raiding team laid a trap near Prachin Khatu Shyam Mandir, Sector-28, Rohini, where they intercepted a car and apprehended the present applicant and co-accused Dalvinder Kumar. Upon searching the vehicle, police allegedly recovered 8 semi-automatic foreign-made The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. sophisticated pistols and 84 live cartridges.

¶3It has come on record that the present applicant was working under the directions of one Jassa who is out of India. Further, the allegations are serious where the applicant is stated to have supplied arms and ammunition to accused persons who were later arrested in the present case. There is enough evidence against the present applicant as can be seen from the status report paragraph no. 3, as is extracted as under:- "3. That, the recovered 08 semi-automatic foreign made sophisticated pistols and 84 live cartridges and Swift Dezire car (PB37H8306) were duly - seized through seizure memo and the present case was registered. During investigation both the above mentioned accused persons were arrested. The accused persons during interrogation disclosed that they were working as per the directions of suspect Jassa who is out of India. It was also revealed that the accused/petitioner Mandeep Singh and co-accused/Dalvinder Kumar had also supplied arms and ammunition to accused the persons Rohan Tomar and Bandhumaan Singh Sekho who were later arrested in the present case.

4.That, the modus .operandi used by the accused persons is that location of a place used to share by the suspect Jassa on WhatsApp or Zangi App and both the above said accused persons used their car to reach at the shared location. Thereafter they send the photos of that location or of any sign boards which identify that place to suspect Jassa, which were further shared with the receiver in the chain. Also the photos of clothes worn by any of the. accused Mandeep Singh or Dalvinder Kumar without the face is shared. with the suspect Jassa, which were also further shared with the receiver in the chain for identification of the accused persons by the receiver. After that the receiver reached at the place and used to receive . the consignment of illegal arms and ammunition."

¶4In State of U.P. v. Amarmani Tripathi1, the Supreme Court observed that the grant or refusal of bail is a matter of judicial discretion that must be exercised judiciously through a balanced evaluation of prima facie satisfaction of guilt, the nature and gravity of the charges, flight risk, and

1 (2005) 8 SCC 21. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. the apprehension of witness tampering or subversion of justice. The relevant para nos. 18-19 are extracted as under: - "18. It is well settled that the matters to be considered in an application for bail are (i) whether there is any prima facie or reasonable ground to believe that the accused had committed the offence; (ii) nature and gravity of the charge; (iii) severity of the punishment in the event of conviction; (iv) danger of the accused absconding or fleeing, if released on bail; (v) character, behaviour, means, position and standing of the accused; (vi) likelihood of the offence being repeated; (vii) reasonable apprehension of the witnesses being tampered with; and (viii) danger, of course, of justice being thwarted by grant of bail [see Prahlad Singh Bhati v. NCT, Delhi [(2001) 4 SCC 280 : 2001 SCC (Cri) 674] and Gurcharan Singh v. State (Delhi Admn.) [(1978) 1 SCC 118 : 1978 SCC

(Cri) 41 : AIR 1978 SC 179] ]. While a vague allegation that the accused may tamper with the evidence or witnesses may not be a ground to refuse bail, if the accused is of such character that his mere presence at large would intimidate the witnesses or if there is material to show that he will use his liberty to subvert justice or tamper with the evidence, then bail will be refused. We may also refer to the following principles relating to grant or refusal of bail stated in Kalyan Chandra Sarkar v. Rajesh Ranjan [(2004) 7 SCC 528 : 2004 SCC (Cri) 1977] : (SCC pp. 535-36, para 11) "11. The law in regard to grant or refusal of bail is very well settled. The court granting bail should exercise its discretion in a judicious manner and not as a matter of course. Though at the stage of granting bail a detailed examination of evidence and elaborate documentation of the merit of the case need not be undertaken, there is a need to indicate in such orders reasons for prima facie concluding why bail was being granted particularly where the accused is charged of having committed a serious offence. Any order devoid of such reasons would suffer from nonapplication of mind. It is also necessary for the court granting bail to consider among other circumstances, the following factors also before granting bail; they are:

a) The nature of accusation and the severity of punishment in case of conviction and the nature of supporting evidence.

b) Reasonable apprehension of tampering with the witness or apprehension of threat to the complainant.

c) Prima facie satisfaction of the court in support of the The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. charge. (See Ram Govind Upadhyay v. Sudarshan Singh [(2002) 3 SCC 598 : 2002 SCC (Cri) 688] and Puran v. Rambilas [(2001) 6 SCC 338 : 2001 SCC (Cri) 1124] .)"

¶19This Court also in specific terms held that: (SCC pp. 536-37, para 14) "[T]he condition laid down under Section 437(1)(i) is sine qua non for granting bail even under Section 439 of the Code. In the impugned order it is noticed that the High Court has given the period of incarceration already undergone by the accused and the unlikelihood of trial concluding in the near future as grounds sufficient to enlarge the accused on bail, in spite of the fact that the accused stands charged of offences punishable with life imprisonment or even death penalty. In such cases, in our opinion, the mere fact that the accused has undergone certain period of incarceration (three years in this case) by itself would not entitle the accused to be enlarged on bail, nor the fact that the trial is not likely to be concluded in the near future either by itself or coupled with the period of incarceration would be sufficient for enlarging the appellant on bail when the gravity of the offence alleged is severe and there are allegations of tampering with the witnesses by the accused during the period he was on bail."

(Emphasis Supplied)

¶5Bearing in mind the aforesaid principle and also the fact that the applicant had six cases against him, out of which he was convicted in three cases and acquitted in the remaining three cases, this Court is not inclined to enlarge the applicant on regular bail.

¶6In view of above, the application stands dismissed.

PURUSHAINDRA KUMAR KAURAV, J AUGUST 21, 2026 ab

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

* IN THE HIGH COURT OF DELHI AT NEW DELHI # CNR No. DLHC010366782026 + BAIL APPLN. 3238/2026 MANDEEP SINGH ALIAS PEETA .....Petitioner Through: Mr. Imran Khan, Mr. Suhail Shah & Ms. Simran Khosla, Advs. versus STATE (NCT OF DELHI) .....Respondent Through: Ms. Shubhi Gupta, APP for State SI Bharat Singh, ARSC Crime Branch. CORAM: HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV