High Court of Gujarat

SANJIV KUMAR RAMKISHAN GOELversusSTATE OF GUJARAT

Disposal: 53-ALLOWED / GRANTED @ ADM.STAGE
Bench: P M RAVAL

Holding

The Court disposed of the anticipatory bail application by imposing conditions of cooperation and a seven‑day notice before arrest, without granting bail.

Summary

The petitioner, Sanjiv Kumar Ramkishan Goel, filed an anticipatory bail application under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, fearing arrest in connection with an FIR alleging an offence under Section 420 of the IPC. The petitioner expressed willingness to cooperate with the investigation and appear before the investigating officer. The Court, while not granting bail, directed the petitioner to be present before the investigating officer on 27‑04‑2026 and mandated that a seven‑day notice be given before any arrest. The Court also instructed the investigating officer to follow Supreme Court pronouncements in Arnesh Kumar, Satender Kumar Antil, and Md. Asfak Alam regarding lawful arrest procedures. The application was consequently disposed with these directions.

Issues considered

Whether anticipatory bail should be granted to the petitioner under Section 482 BNSS in a case involving alleged Section 420 IPC offence
Whether the Court can impose conditions such as mandatory cooperation and prior notice before arrest

Legislation cited

Bharatiya Nagarik Suraksha Sanhita, 2023s. 482
Indian Penal Code, 1860s. 420

Subjects

anticipatory bailSection 482 BNSSSection 420 IPCinvestigation cooperationnotice before arrestSupreme Court guidelines

Judgment

     R/CR.MA/8935/2026                             ORDER DATED: 20/04/2026




            IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

R/CRIMINAL MISC.APPLICATION (FOR ANTICIPATORY BAIL) NO. 8935
                          of 2026

==========================================================
                         SANJIV KUMAR RAMKISHAN GOEL
                                     Versus
                               STATE OF GUJARAT
==========================================================
Appearance:
NISARG S SHAH(8886) for the Applicant(s) No. 1
MR. KRUTIK A. PARIKH, APP for the Respondent(s) No. 1
==========================================================

 CORAM:HONOURABLE MR.JUSTICE P. M. RAVAL

                               Date : 20/04/2026

                                 ORAL ORDER


1.     By way of the present application under Section 482 of the
Bharatiya Nagarik Suraksha Sanhita, 2023 (for short “BNSS”), the
applicant has prayed for anticipatory bail in the event of arrest in
connection with the FIR being C.R. No. 11210067260143 of 2026
registered with Saroli Police Station, Surat City, for the offence
punishable under Section 420 of the Indian Penal Code, 1860.


2.     At the outset, the learned advocate for the applicant would
submit that the offence alleged in the impugned FIR are the one in
which maximum punishment prescribed for is upto 7 years.
Accordingly, on instructions, he states that the applicant is ready and
willing to join the investigation and will appear before the
investigating officer as per direction of this Court.


3.     Considering the above, the applicant is hereby directed to

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       R/CR.MA/8935/2026                                                               ORDER DATED: 20/04/2026




remain present before the Investigating Officer concerned on
27.04.2026 and co-operate with the investigation and if at all the
Investigating Officer deems it fit to arrest the applicant, a 7 days’
prior notice shall be given to him. Further, the Investigating Officer
is directed to scrupulously follow the proposition of law as settled by
the Hon’ble Supreme Court in the cases of Arnesh Kumar v. State
of Bihar, reported in (2014) 8 SCC 273, Satender Kumar Antil v.
Central Bureau of Investigation & Anr., reported in (2022) 10 SCC
51 and in Md. Asfak Alam v. State of Jharkhand & Anr., reported
in 2023 SCC OnLine SC 892 and also inform about the grounds of
arrest, if needed, to learned Magistrate and even the learned
Magistrate before mechanically authorizing the detention of the
applicant, shall follow the dictum of the Hon’ble Supreme Court in
the aforesaid decisions.


4.         With aforesaid directions, this application stands disposed of.
Direct service is permitted.



                                                                                                (P. M. RAVAL, J)
NITIN MAKWANA

Original copy of this order has been signed by the Hon'ble Judge.
Digitally signed by: NITIN INDRAVADAN MAKWANA(HCW0110), ENGLISH STENOGRAPHER GRADE I, at High Court of Gujarat on 20/04/2026 17:56:32




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