Punjab & Haryana HC Grants Bail to Alleged Lawrence Bishnoi Gang Member After Four Years in Pre-Trial Custody
Justice Manisha Batra granted bail to Karambir @ Karmu, accused of facilitating arms and harbouring killers in a 2022 double murder, citing the limited and indirect role ascribed to him and the remote prospect of an early trial.
The High Court of Punjab & Haryana at Chandigarh has ordered the release on bail of Karambir @ Karmu, accused in a double murder registered at Police Station Pataudi, District Gurugram. Justice Manisha Batra, sitting singly, held on 30 July 2026 that the material against the petitioner — resting substantially on co-accused disclosure statements — did not justify continued pre-trial detention after over four years in custody, particularly given the slow pace of trial where only 38 of 91 prosecution witnesses had been examined. The ruling distinguished between the direct commission of murder under Section 302 IPC and the remote, facilitative role alleged against the petitioner.
The Double Murder at Pataudi and the FIR
FIR No. 119, dated 25 February 2022, was registered at Police Station Pataudi under Sections 148, 149, 302, 201 and 120-B of the Indian Penal Code. The complainant, Ajit Singh, alleged that on the morning of 25 February 2022, accused Ajay @ Jaildar arrived with four or five others in a Scorpio vehicle and a motorbike, all armed with firearms, at the house of Dharambir Lumberdar. The group opened fire on Ajit Singh’s brother Paramjit Singh. Separately, accused Sandeep Goriyawas, Dinesh and Rohit fired on another brother, Sujit Singh. Both Paramjit Singh and Sujit Singh were taken to hospital and declared dead on arrival.
Ajit Singh alleged in his complaint that the attack was orchestrated at the behest of one Dhanpat, his nephew Jassu, and their sons.
How Karambir Came to Be Arrested
After registration of the FIR, police obtained CCTV footage from the vicinity and arrested co-accused Akshay. On interrogation, Akshay gave a disclosure statement admitting involvement in a conspiracy to murder the two victims. Further investigation led to the petitioner being nominated as an accused. Karambir was arrested on 15 March 2022 and, on interrogation, gave a disclosure statement admitting involvement in the crime. He also got recovered the Scorpio vehicle bearing registration No. HR-76-D-1227, which he allegedly used to help the assailants flee the crime scene, along with one dongle and one mobile phone. Investigation against him was stated to be complete.
The Role Alleged Against the Petitioner
The prosecution did not allege that Karambir was among the shooters or was present at the spot when the firing took place. His attributed role was threefold: facilitating the illegal procurement of firearms from one Satendra @ Goldy Brar at Rishikesh; taking co-accused persons to a kothra of co-accused Ajay in the fields of village Goriyawas; and facilitating the safe escape of the assailants after the murders.
The State, assisted by counsel for the complainant, argued that Karambir was an active member of the Lawrence Bishnoi gang and had remained in regular contact with co-accused Ajay @ Jaildar and Naresh Sethi through encrypted platforms — Signal App and WhatsApp — using internet dongles and mobile phones. He was described as a harbourer who sheltered the principal accused after the offence, provided weapons to the assailants, and helped them screen themselves from legal punishment by causing the disappearance of evidence. The State urged that there were real chances of his committing similar offences, intimidating witnesses, or absconding if released.
Petitioner’s Argument: Parity with Co-Accused Already on Bail
Counsel for the petitioner, Mr. S.S. Nain, pressed several grounds. Karambir was not named in the FIR. No specific act at the crime scene was attributed to him. No firearm or other weapon was recovered from him. He was not nominated by any other accused in their statements. The case against him rested on disclosure statements of co-accused and circumstantial inference, with no direct evidence connecting him to the offences.
Crucially for the parity argument, co-accused Mohit @ Babu Maan, Vishnu @ Ghochu, Ravi @ Pehalwan and Ajay @ Ajju had all been granted bail. Counsel argued that Karambir’s case stood on equal or better footing and that denying him bail solely because he was involved in two other cases was not a sufficient ground. His custody since 15 March 2022 — over four years and four months at the time of the order — and the bleak prospects of an early trial were urged as militating against his continued detention under Article 21 of the Constitution of India.
How Justice Batra Reasoned Through the Bail Claim
Justice Batra accepted that the offences were serious, involving the murder of two persons, but held that the court must test whether the material against the specific accused justified his continued pre-trial incarceration. The linkage between the petitioner and the supply of firearms, as well as the harbouring allegation, rested primarily on disclosure statements of co-accused and circumstantial inference. The court treated this as material best assessed by the trial court on a thorough evaluation of the evidence at trial.
The court drew a clear line between the petitioner’s ascribed role and direct commission of the offence. The role of a conduit or facilitator in the procurement of arms and in harbouring co-accused was described as “distinct and remote offence from the direct commission of offence punishable under Section 302 of IPC.” This distinction was central to the decision to allow bail.
On the question of delay, the court recorded that only 38 of 91 prosecution witnesses had been examined. With the trial set to take considerable time, the court held that further pre-trial incarceration would not serve the ends of justice. The period of custody — approximately four years and four months — weighed heavily in the analysis.
Conditions Imposed on Release
The court allowed the petition and directed the petitioner to be released on bail on furnishing personal and surety bonds to the satisfaction of the trial court, Chief Judicial Magistrate, or Duty Magistrate concerned. The following conditions were attached:
- Karambir must appear before the trial court on each date of hearing unless exempted.
- He must not tamper with evidence or attempt to influence witnesses in any manner.
- He must surrender his passport, if any, furnish details of his cell phone and Aadhaar card, and must not change his mobile number during the pendency of the trial.
- He must visit the concerned Police Station on the first Monday of every alternate month, mark his presence before the Station House Officer, and in case of non-appearance, the SHO must intimate the trial court.
The court clarified that all observations made in the order were solely for the purpose of deciding the bail petition and would have no bearing on the merits of the case at trial.
Order
CRM-M-32145-2026 (O&M) was allowed by Justice Manisha Batra on 30 July 2026. Karambir @ Karmu, accused in FIR No. 119 of 2022 at Police Station Pataudi, District Gurugram, is to be released on regular bail subject to the conditions set out above. The judgment was pronounced on the same date as reservation, 30 July 2026, and uploaded on 30 July 2026. It is marked as a speaking and reasoned order.