Delhi High Court · 2025

$~50 * IN THE HIGH COURT OF DELHI AT NEW DELHI+ BAIL APPLN. 3943/2025 & CRL.M.A. 30741/2025 PRAVEEN DHAMA .....Petitioner Through: Mr. Mohit Mathur, Sr. Advocate with Mr. Akash Nagar, Manohar Kumar, Mr. Manish Kumar, Mr. Apoorv Paliya, Mr. Vikram Choudhary, Mr. Vignesh Ramanathan, Mr. Harsh Gautam and Mr. George Tomes, Advocates versus STATE OF NCT OF DELHI & ANR. .....Respondents Through: Mr. Naresh Kumar Chahar, APP for the State with ACP Hans Raj, North-West District and Ms. Amisha Dahiya, Advocate Mr. Samarth Goel with Mr. Rudrojyoti Nath Ray, Advocates for complainant CORAM:HON'BLE DR. JUSTICE SWARANA KANTA SHARMAO R D E R% 15.10.2025CRL.M.A. 30740/2025 (exemption)1.Allowed, subject to all just exceptions. 2.Application stands disposed of. BAIL APPLN. 3943/2025 & CRL.M.A. 30741/20253.By way of the present application, the applicant seeks grant of anticipatory bail in case arising out of FIR bearing no. 280/2025, registered at Police Station Maurya Enclave, Delhi for the commission of offence This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/10/2025 at 11:51:17 punishable under Sections 82(1)/85/89/316(2)/351(2)/3(5) of the Bharatiya Nyaya Sanhita, 2023 (hereafter ‘BNS’) and Section 3(1)(r)(s) of the SC/ST Act, 1989. 4.Briefly stated, the facts of the present case are that the complainant, ‘S’, aged about 29 years, had lodged a complaint on 27.06.2025 at CAW Cell, and after conducting an enquiry, the CAW Cell had forwarded the same to P.S. Maurya Enclave for registration of FIR. As per the FIR, the complainant, belonging to a Scheduled Caste, had come in contact with the accused Praveen Dhama through a mutual acquaintance, and he had induced her into a relationship by representing himself as unmarried and promising marriage. It is alleged that on this pretext, the accused had established sexual relations with the complainant against her consent and repeatedly coerced her into undergoing multiple abortions, including administering medicines and taking her to hospitals. It is further alleged that the accused had subjected the complainant to severe physical and mental cruelty, confined her unlawfully, and threatened her life to compel compliance with his demands. It is alleged that during the initial period of the relationship, the accused had coerced the prosecutrix to lend him money, had misappropriated her salary, and compelled her to finance his gambling and lifestyle, including repeated online betting. It is further alleged that he had misused her identity documents and a signed blank cheque to secure loans from third parties, diverting substantial funds to himself and his associates without her knowledge. The complainant alleges that the accused had sold her personal property, including a Yamaha Fasino scooty and various household items, without her consent, and had repeatedly misappropriated her valuables, including pledging her gold and jewelry to secure loans. It is This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/10/2025 at 11:51:17 alleged that despite repeated promises of marriage, the accused had avoided formalizing the relationship, causing prolonged mental and emotional trauma to the prosecutrix. Eventually, it is alleged that the complainant and the accused had solemnized their marriage at Tis Hazari Court, Delhi on 24.05.2023, and had subsequently got it registered at Nand Nagri, Ghaziabad on 12.03.2024. Post-marriage, it is alleged that the accused had continued to assault the complainant physically, misappropriate her valuables, and deny her basic household and medical expenses. It is alleged that the accused had repeatedly hurled caste-based abuses at the complainant and her family, humiliating and degrading her on account of her Scheduled Caste status, including statements aimed at publicly insulting her and asserting her supposed inferiority. It is further alleged that the accused had contracted a second marriage with another woman ‘AK’, without dissolving his marriage with the complainant, and had continued to threaten her and her family to force them to agree to a mutual divorce. It is also alleged that the accused had misrepresented himself as holding a government post of SDM and had demanded money and loans from the complainant and her family under this false pretext. It is further alleged that he had diverted funds from her accounts, including withdrawals from her bank and credit card, and had compelled her to take additional loans in her name for his personal benefit. The complainant has alleged that she was repeatedly sexually exploited, physically assaulted, financially exploited, humiliated on caste grounds, and subjected to threats to her life and that of her family over a period of several years. During investigation, the caste certificate of the complainant was verified from the concerned SDM, which confirmed that she belongs to Raiger caste (Scheduled Caste). Statements of witnesses have also been This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/10/2025 at 11:51:17 recorded by the I.O. 5.The learned senior counsel appearing for the applicant/accused argues that the applicant has been falsely implicated in the present case with the motive of extorting money from him. It is submitted that there are certain WhatsApp chats, also annexed with the bail application, wherein the complainant can be seen threatening the applicant and demanding a sum of ₹1.5 crore and a house, and the present case has been instituted as a consequence of the said demand. It is also pointed out that one of the chats also reveal that the complainant had bribed a senior police official for getting the present FIR registered. It is further contended that the alleged offence under the SC/ST Act is not made out, as the alleged incident admittedly did not occur within public view, which is an essential ingredient. It is also argued that a plain reading of the FIR reveals that the allegations of caste-based abuse made against the complainant are vague, and devoid of any specific details such as time, place, and manner of occurrence, etc. It is thus argued that offence under SC/ST Act is not even prima facie made out against the accused. The learned senior counsel further submits that the applicant is willing and ready to join the investigation. In these circumstances, it is prayed that the applicant be granted anticipatory bail. 6.The learned APP for the State, on the other hand, argues that the applicant/accused had falsely represented himself as an SDM appointed in Himachal Pradesh; however, upon verification, this claim was found to be false. It is further argued that the applicant/accused had used the complainant’s bank account for the purpose of gambling. It is also argued This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/10/2025 at 11:51:17 that on several occasions, the applicant/accused had directed the complainant to transfer money either to his own account or to the accounts of his associates. It is also argued that despite being married to the complainant, the applicant got married for the second time. Furthermore, despite service of notice, the applicant/accused has failed to join the investigation. It is also stated that since prima facie allegations of commission of offence under SC/ST Act have been levelled against the applicant, the applicant is not entitled to grant of anticipatory bail. 7.This Court has heard arguments addressed on behalf of the applicant, as well as the State and the complainant, and has perused the material on record. 8.In the present case, firstly, the complainant has alleged that the applicant had made casteist remarks and abused her, and the FIR records specific allegations in this regard. Insofar as the contention of the applicant that no such abuse was made “in public view” is concerned, at this stage, the allegations find corroboration from the statement of Ms. ‘GD’, recorded under Section 180 of the BNSS, wherein she has stated that the applicant had used caste-based and abusive language against the complainant in her presence. Furthermore, another witness, Sh. ‘S’, has stated that on 24.05.2025, when he visited the complainant’s residence, the applicant and his family members were present there and were pressurising the complainant to agree to a divorce, during which they also hurled casteist remarks and abuses towards her. In view of these statements recorded during the course of investigation, the contention of the applicant that even prima facie no offence under the SC/ST Act is made out, and therefore he is This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/10/2025 at 11:51:17 entitled to anticipatory bail, cannot be accepted by this Court. 9.Secondly, as regards the allegation that the applicant had falsely represented himself as an SDM or IAS officer, it is noted that though the applicant has denied the same, the learned APP for the State has drawn this Court’s attention to certain screenshots of WhatsApp conversations placed on record by the complainant, wherein the applicant can be seen sharing an identity card purportedly showing him as “Secretary to the State of Himachal Pradesh,” along with newspapers clippings mentioning his selection as an SDM in Himachal Pradesh. The complainant has further alleged that on the pretext of arranging money to bribe certain officials in Himachal Pradesh for his “late joining,” loans amounting to about ₹22 lakhs were sanctioned in her name, which amount was subsequently transferred by her into the accounts of the applicant, Praveen Dhama, in different banks. Further, during the course of investigation, the father of the applicant, Mr. Jaipal, had joined the investigation and stated that he did not possess any documents to confirm his son’s selection as SDM in Himachal Pradesh and sought 10–15 days’ time to provide such records. Similarly, the mother of the applicant, Smt. Nirmala, also failed to produce any relevant documents. The learned APP has further produced before this Court a letter dated 13.10.2025 issued by the Special Secretary (Personnel), Government of Himachal Pradesh, categorically stating that no officer by the name of Praveen Dhama is serving either in the Indian Administrative Service cadre of Himachal Pradesh or in the Himachal Pradesh Administrative Services. 10.Moreover, this Court notes that the applicant is also alleged to have pressurised the complainant to terminate her pregnancy. The statement of This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 17/10/2025 at 11:51:17 Ms. ‘GD’, a friend of the complainant, recorded under Section 180 of the BNSS, reflects that the complainant was pregnant with the child of the applicant and that the applicant had compelled her to undergo termination of the said pregnancy, pursuant to which the complainant was constrained to do so. It is further alleged that the applicant has committed the offence of bigamy by solemnising marriage with another woman while his marriage with the complainant was still subsisting. In this regard, the learned APP for the State has placed on record a copy of the marriage invitation card of the applicant’s alleged marriage with Ms. A.K. 11.The learned APP, on instructions from the I.O., has further submitted that custodial interrogation of the applicant is required for recovery of the cheated and extorted amount obtained from the complainant, as well as for verification of the alleged financial transactions and transfer of funds between the complainant and the applicant. 12.In view of the overall facts and circumstances of the case, and particularly in light of the prima facie allegations disclosing commission of offences under the provisions of the SC/ST Act, this Court does not find any ground to extend the benefit of anticipatory bail to the applicant. 13.The bail application is accordingly dismissed. 14.Nothing expressed hereinabove shall tantamount to an expression of opinion on the merits of the case. 15.The order be uploaded on the website forthwith. DR. SWARANA KANTA SHARMA, JOCTOBER 15, 2025/ns