Mohd. Farhan Vs State of Chhattisgarh (Chhattisgarh High Court)
The Chhattisgarh High Court considered a first anticipatory bail application filed under Section 482 of the Bhartiya Nagarik Suraksha Sanhita, 2023, by an applicant apprehending arrest in connection with a GST-related offence registered as Crime No. DCST/BIU/NRD/02/2025. The crime was registered at the State Tax Department’s BIU Police Station, Naya Raipur, for alleged offences under Sections 67 and 132 of the CGST/CGGST Act, 2017.
According to the prosecution, officers of the CGST Department conducted a search under Section 67 on 12.09.2025 at the applicant’s office on allegations of involvement in creating bogus firms and facilitating fake e-way bills. During the search, documents and digital records relating to GST registrations were seized, and allegations were raised regarding irregular rent agreements. Cash of ₹2,48,000 was recovered from the applicant’s premises, while additional cash and gold recovered from another person were sought to be linked to the applicant. The Department examined records of 174 firms and treated several as suspicious. Multiple summons were issued to the applicant on different dates, and upon rejection of anticipatory bail by the Sessions Court on 08.10.2025, fresh summons were again issued, leading to the present application.
The applicant contended that the allegations were based on suspicion and misappreciation of facts. He asserted that he was a freelance accountant acting on client-provided information and that GST registration was a system-driven process involving Aadhaar authentication, physical verification, and departmental approval, making forgery at his end implausible. It was argued that the case rested entirely on documentary and digital material already seized or available on official portals, with no further recovery pending. The applicant expressed willingness to cooperate with the investigation and submitted that custodial interrogation was unnecessary in a documentary investigation.
