Allahabad High Court

RAHISH PALversusSTATE OF U.P.

Decided: 30 September 2026
Bench: RAJIV LOCHAN SHUKLA

Holding

The Court held that the applicant, not being a beneficiary of the alleged forged entries and given the extraordinary delay in the FIR, is entitled to anticipatory bail under Section 482 CrPC.

Summary

The Allahabad High Court entertained an anticipatory bail application under Section 482 CrPC filed by Rahish Pal, a revenue officer (Lekhpal), who feared arrest in a case (Crime No.237 of 2025) alleging offences under IPC sections 420, 467, 468 and 471. The applicant claimed false implication, noting that the FIR was lodged 22 years after the alleged incident and that he was not the beneficiary of the purported forged sale deed. The State opposed bail, arguing that the applicant, as the Lekhpal, was a key participant in the alleged forgery and highlighted his prior criminal record. The Court observed that the delay in filing the FIR and the applicant’s lack of benefit from the forged entries mitigated the seriousness, and that his past cases had been resolved or bail had been granted. Consequently, the Court granted anticipatory bail with standard conditions, emphasizing that the order was limited to the bail application and not an opinion on the merits of the criminal case.

Issues considered

Whether the applicant is entitled to anticipatory bail under Section 482 CrPC despite the nature of the alleged offences (IPC 420, 467, 468, 471) and his prior criminal history.
Whether the 22‑year delay in lodging the FIR defeats the grant of anticipatory bail.
Whether the applicant’s role as Lekhpal makes him a key participant in the alleged forgery, warranting denial of bail.

Legislation cited

Code of Criminal Procedure, 1973 — s. 482
Indian Penal Code — s. 420, 467, 468, 471

Subjects

anticipatory bail
Section 482 CrPC
IPC offences
forgery
revenue records
delay in FIR
bail conditions
false implication

Judgment

HIGH COURT OF JUDICATURE AT ALLAHABAD
CRIMINAL MISC. ANTICIPATORY BAIL APPLICATION U/S 482 BNSS No.
- 10297 of 2026

Rahish Pal
.....Applicant(s)
Versus

State of U.P.
.....Opposite
Party(s)

Counsel for Applicant(s) : Pankaj Kumar Mishra
Counsel for Opposite Party(s) : G.A.

Court No. - 71
HON'BLE RAJIV LOCHAN SHUKLA, J.

1. Heard Learned counsel for the applicant and Learned A.G.A. for the
State as well as perused the record.

2. The present anticipatory bail application has been filed on behalf of the
applicant in Case Crime no.237 of 2025, under section 420, 467, 468, 471
IPC, Police Station- Chaubia, District-Etawah, with a prayer to enlarge
him on anticipatory bail as the applicant apprehends his arrest in the
abovementioned case.

3. Learned counsel for the applicant has contended that the applicant has
been falsely implicated in the present case. The applicant at the relevant
point of time was the Lekhpal. The allegations are of the co-accused
Indrapal getting his name mutated in the revenue records on the basis of
an order dated 23.07.2003 passed by the Assistant Consolidation Officer.
Learned counsel has submitted that the F.I.R. has been lodged after 22
years of the occurrence on 28.12.2025. Co-accused Indrapal Singh Yadav
has been granted regular bail by this Court in Criminal Misc. Bail
Application No.8398 of 2026. The applicant is still working as Lekhpal.
The applicant has a criminal history of three cases; in one case the
applicant has been granted bail by this Court, in another case the applicant
is on interim bail under the orders of this Court and in Case Crime No.317
of 2018 a final report has been submitted and the protest petition filed by
the informant has also been dismissed.
NABAIL No. 10297 of 2026
2

4. Learned A.G.A. has opposed the prayer for anticipatory bail but does
not dispute the explanation given by the applicant of his criminal history.
Learned A.G.A. has stated that the entries in the revenue records were
made on the basis of a fake sale deed. The applicant being the Lekhpal at
the relevant point of time was one of the key persons in the said forgery.
Learned counsel has further submitted that the applicant has three other
cases to his credit of like nature which indicate the propensity of the
applicant to repeat such crimes and he may not be considered for grant of
anticipatory bail.

5. I have considered the submissions made by the Learned counsels for
the parties.

6. The applicant is not the beneficiary of the alleged forged entries
supposedly obtained on the basis of a fake sale deed. The FIR has been
lodged with an excessive delay of 22 years. Co-accused Indrapal Singh
Yadav has been granted regular bail by this Court in Criminal Misc. Bail
Application No.8398 of 2026. The criminal history of the applicant has
been duly explained.

7. Taking into account the facts and circumstances of the case, I deem it
appropriate to enlarge applicant on anticipatory bail.

8. In view of the above, the anticipatory bail application of the applicant
is allowed.

9. In the event of the arrest of the applicant-Rahish Pal, he shall be
released forthwith in the aforesaid case crime on anticipatory bail on
furnishing a personal bond and surety to the satisfaction of the Station
House Officer of the police station/Court concerned with the following
conditions:-

i. the applicant shall make himself available for interrogation by a police
officer as and when required;

ii. that the applicant shall not, directly or indirectly make any inducement,
threat or promise to any person acquainted with the facts of the case so as
to dissuade him from disclosing such facts to the Court or to any police
NABAIL No. 10297 of 2026
3

officer;

iii. that the applicant shall not leave India without the previous permission
of the Court;

iv. that the applicant shall not pressurize/intimidate the prosecution
witness;

10. In case of breach of any of the above conditions, the Court concerned
shall be at liberty to cancel the bail.

11. It is made clear that observations made hereinabove are exclusively
for deciding the instant anticipatory bail application and are not to be
considered to be an opinion on the merits of the case.

(Rajiv Lochan Shukla,J.)
October 1, 2026
A. Pandey

Digitally signed by :-
ANAND PANDEY
High Court of Judicature at Allahabad

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