The Punjab and Haryana High Court has upheld the decision of the Special CBI Court in Panchkula to summon five senior officials — including former IAS officer Rajeev Arora (1987 batch) — as additional accused in the controversial Manesar land deal case. The court dismissed petitions challenging the trial court’s order, rejecting claims of procedural illegality.
A bench led by Justice Manjari Nehru Kaul ruled that the Special CBI Court acted within its jurisdiction. The petitioners had argued that they were initially listed as prosecution witnesses and that no new evidence had emerged since the chargesheet was filed to justify their summoning as accused. However, the High Court found no merit in this argument.
“There is no illegality or infirmity in the impugned order passed by the learned Special Court in summoning the petitioners. The challenge to the order is, therefore, liable to be rejected. Consequently, all the petitions stand dismissed,” the court observed.
Officers Summoned
The trial court had issued summons in December 2020 to the following officials, in addition to 33 others, including former Haryana Chief Minister Bhupinder Singh Hooda, already facing charges:
Rajeev Arora, former IAS officer and Managing Director, HSIIDC (2005–2012)
Surjit Singh, former Chief Town Planner, HSIIDC
Dhare Singh, former Chief Town Planner, Department of Town and Country Planning
Kulwant Singh Lamba, then Deputy Superintendent, Town and Country Planning
D.R. Dhingra, then Director, Industries
Applicability of Sanction Under PC Act
The High Court also addressed the applicability of Section 19 of the Prevention of Corruption Act. It held that the 2018 amendment requiring prior sanction for prosecuting retired public servants does not apply retrospectively. Since the trial court took cognisance of the case in March 2018, no sanction was necessary for retired officials.
In Rajeev Arora’s case, who was still in service when proceedings began, the court clarified that it did not order the competent authority to grant sanction but merely directed that the relevant material be submitted for its consideration.
Threshold for Summoning
The bench emphasized that at the stage of summoning, the trial court only needs to determine whether a prima facie case exists. It is not required to assess the strength or credibility of the evidence or conduct a mini-trial.
“The court is empowered to summon any person found prima facie involved in the commission of the offence based on the material placed before it. There is no legal mandate for the court to direct further investigation if it disagrees with the police report,” the court noted.
Background: The Manesar Land Deal Case
The case pertains to a 2004 notification issued by the Haryana government under Section 4(1) of the Land Acquisition Act, 1894, for acquiring 912 acres in Manesar, Lakhnaula, and Naurangpur villages. Fearing acquisition, landowners allegedly sold their properties at low rates, causing a reported loss of ₹1,500 crore, according to the CBI.
In 2007, the then Director of Industries ordered the release of the land in favor of private entities rather than the original owners, purportedly in violation of government policy. The CBI launched its investigation in 2015 and filed an 80,000-page chargesheet in 2018 naming 34 accused, including Bhupinder Singh Hooda.
The summoning of the additional five officials was challenged in December 2020, resulting in a stay on trial proceedings. With the High Court’s decision dated May 15, 2025, the stay is now lifted, and the trial is set to resume.
Petitions filed by certain builders and private individuals challenging the framing of charges remain pending. Notably, Mr. Hooda has not contested the trial court’s order.
