Punjab & Haryana HC Denies Anticipatory Bail in LLP Partnership Dispute Involving Alleged Forgery

Narendra Singh ALS

Date: 24.10.2026

The Punjab and Haryana High Court has declined anticipatory bail to two partners of M/s GLK Homes LLP in a case involving allegations of forged retirement documents, unpaid settlement amounts, and an alleged attempt to remove a partner from the business.

Background of the dispute

The case arose from a dispute within M/s GLK Homes LLP, a firm incorporated in June 2020. The complainant, Devender Singh, alleged that he had joined the firm as a partner and contributed to its business and management. According to the complaint, disagreements later developed between the partners, after which the accused allegedly conspired to exclude him from the firm and deny him his share in its capital, profits, and goodwill.

The complainant alleged that the accused had offered to dissolve the business arrangement by paying him β‚Ή13.50 crore. While β‚Ή50 lakh was transferred through RTGS, he claimed that the remaining amount was not paid. Three cheques dated 1 April 2022 were allegedly issued for the balance, but the account from which they were drawn had been closed.

He further alleged that a retirement deed was fabricated to show that he had voluntarily retired from the LLP after receiving a full and final settlement. The allegedly forged document was submitted to the Registrar of Companies to create a record that he had left the firm.

Petitioners’ defence

The petitioners argued that the matter was essentially a delayed commercial dispute concerning land transactions and partnership arrangements. They maintained that β‚Ή50 lakh had been paid to the complainant because it represented his agreed capital contribution to the LLP, not a settlement of β‚Ή13.50 crore.

Their case was that the alleged larger payment arrangement was oral, undocumented, and implausible. They also contended that the complainant had resigned voluntarily in September 2020 and that his entitlement to payment depended on conditions relating to acquisition of land and regulatory approvals.

The petitioners relied on a video recording which they claimed showed voluntary execution of the relevant documents. They also stressed that they had cooperated with the investigation and that the disputed original documents were already in the investigating agency’s possession.

Land transaction context

The dispute was connected with approximately 11.26 acres of land in Village Sihi, Faridabad. The petitioners described a sequence of earlier agreements involving landowners, M/s Bonanza Promoters Pvt. Ltd., M/s Crown Township Pvt. Ltd., and entities associated with the complainant.

According to their submissions, M/s GLK Homes LLP acquired the land in July 2020 through registered transactions worth more than β‚Ή47 crore. The petitioners claimed that they had arranged substantial funds for the transaction after the complainant and another associate were unable to finance the project.

They also referred to a separate dispute involving M/s Shail Developers Ltd., which had advanced β‚Ή2.50 crore. That amount was later returned by M/s GLK Homes LLP under a compromise arrangement.

Forensic findings weighed heavily with the Court

The State and the complainant opposed anticipatory bail, relying on findings of the Regional Forensic Science Laboratory, Bhondsi. The forensic examination reportedly found the compromise deed, retirement deed, and board-meeting minutes to be forged.

Most significantly, the Court noted that the complainant’s signatures on the disputed retirement documents were found to have been lifted from another document. The Court also found that the petitioners’ video-recording claim did not displace the forensic material at the bail stage.

The Court observed that it appeared doubtful that the complainant would have resigned shortly after sale deeds were executed in the LLP’s favour in July 2020 merely in exchange for β‚Ή50 lakh, particularly given the scale of the underlying land transaction and the complainant’s asserted financial involvement.

Court’s decision

Justice Shalini Singh Nagpal held that anticipatory bail is an extraordinary form of protection and cannot be claimed as a matter of right. While the Court acknowledged that custodial interrogation might not be necessary solely because the petitioners had previously joined the investigation, it held that this was not enough to justify pre-arrest bail.

The seriousness of the alleged forgery, the forensic findings, and the petitioners’ attributed role were treated as decisive factors. The Court concluded that no strong or exceptional circumstances had been shown to warrant anticipatory bail.

The petition was therefore dismissed.

Key legal takeaway

The decision illustrates that in allegations of business-partnership fraud, the existence of documentary evidence does not automatically favour anticipatory bail. Where forensic material indicates that signatures or corporate records may have been fabricated, courts may treat the allegations as serious enough to deny pre-arrest protection even if the dispute also has commercial and civil dimensions.

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