This compilation indexes twelve High Court rulings — spanning March 2022 to April 2026 — in which accused persons filed bail applications arising from prosecutions under Section 132(1)(i) of the Central Goods and Services Tax Act, 2017 (and its state mirror legislation). The cases are drawn from the Gujarat, Telangana, Punjab-Haryana, Rajasthan, Allahabad, and Madhya Pradesh High Courts and involve allegations ranging from fake-firm creation and bogus Input Tax Credit (ITC) availment to fraudulent invoice generation. This index is intended for GST litigation researchers, in-house legal teams, and law-firm associates tracking judicial trends in CGST criminal enforcement.

Research index only. This page is a structured case-law reference. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Readers must consult qualified legal counsel and verify each ruling against the full text of the judgment before relying on it.

The statutory framework in one paragraph

Section 132 of the Central Goods and Services Tax Act, 2017 creates criminal liability for specified GST offences. Section 132(1)(i) provides that any person who abets or causes another person to commit any of the offences described in clauses (a) through (h) of sub-section (1) shall be punishable with the penalties prescribed therein — making abetment of the substantive CGST offences (such as fraudulent availment of ITC, issuance of invoices without actual supply of goods or services, and collection of tax but failure to deposit the same) an independent cognizable and non-bailable criminal offence where the amount of tax evaded or ITC involved exceeds the threshold specified in the Act. The section is typically invoked alongside one or more of the substantive clauses (most commonly 132(1)(b) and 132(1)(c)) in prosecution complaints filed by the Directorate General of GST Intelligence (DGGI) and state enforcement wings.

The 12 rulings

1. Vishalkumar Rameshbhai Gondaliya vs State Of Gujarat

Bench: Gujarat High Court
Date: 20 April 2026
Sections engaged: 132(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The applicant filed this application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking regular bail before chargesheet in connection with File No. DGGI/INV/GST/2590/2025 GR B – DGGI – Surat, for the offence punishable under the CGST Act, 2017. The Court issued Rule and the learned APP waived service of notice on behalf of the State; the matter was heard at the admission stage per the source preview.

2. Shri. Rishi Nand Kishore Gupta vs Union Of India

Bench: Telangana High Court
Date: 23 March 2026
Sections engaged: 132(1)(i), 70
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner — described in the source preview as aged 57 years, MD & CDO of FNO Payments Bank — filed Writ Petition No. 6657 of 2026 before the Telangana High Court. The petition was heard by a division bench; the source preview records appearances of senior counsel on both sides including representation by the Additional Solicitor General of India for the respondents, and notes reference to several Supreme Court and High Court precedents in the head-note, indicating a substantive challenge was raised.

3. Shivam Gupta vs State Of Punjab And Others

Bench: Punjab-Haryana High Court
Date: 23 February 2026
Sections engaged: 132(1)(c), 132(1)(i), 67(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two connected petitions — CRM-M-503-2026 filed by Shivam Gupta and CRM-M-2739-2026 filed by Vaishno Dass — were heard together and the full judgment was pronounced on 23 February 2026 after being reserved on 13 February 2026. The source preview confirms the full judgment (not merely the operative part) was pronounced and uploaded on the same date, indicating a reasoned order was delivered on the bail applications.

4. Jagdish S/O Amraram vs Union Of India

Bench: Rajasthan High Court - Jaipur
Date: 6 December 2025
Sections engaged: 132(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (S.B. Criminal Miscellaneous Bail Application No. 13782/2025) was filed by Jagdish S/o Amraram, lodged in Central Jail, Jaipur, and was heard connected with S.B. Criminal Miscellaneous Bail Application No. 13655/2025 filed by a co-accused. Arguments concluded on 3 December 2025, judgment was reserved on the same date, and the full judgment was pronounced on 6 December 2025; DGGI was represented by specialised counsel including senior DGGI officers per the source preview.

5. Kamlesh Mishra vs Union Of India

Bench: Allahabad High Court
Date: 23 September 2025
Sections engaged: 132(1)(i), 70
Outcome: Outcome not specified in source
Procedural / substantive ground: Three applicants — Kamlesh Mishra, Rohit Garg, and Sagar Garg — filed separate bail applications under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 during the pendency of trial in Case No. DGGI/INTL/3318/2024 (titled Union of India, DGGI, Ghaziabad Regional Unit vs. Shri Kamlesh Mishra and others). The Allahabad High Court heard the applications together; the matter arises from a DGGI prosecution under the CGST Act, 2017 per the source preview.

6. Dheeraj Saini vs Union Of India

Bench: Allahabad High Court
Date: 4 December 2024
Sections engaged: 132(1)(i), 70
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 33795 of 2024, Neutral Citation 2024:AHC:191863) was filed by Dheeraj Saini seeking bail in Case No. 633 of 2023 registered by DGGI/GRU Kaushambi, Ghaziabad. The source preview recounts that a search operation was conducted on 15 May 2023, leading to the detection of a racket involving 44 non-existent or non-operational firms controlled by one Deepak Kumar, with allegations of availing ineligible ITC of Rs. 123.38 crores and passing on ineligible ITC of Rs. 141.18 crores.

7. Pradip Kumar Jain vs Union Of India

Bench: Allahabad High Court
Date: 29 May 2024
Sections engaged: 132(1)(b), 132(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two connected bail applications — Criminal Misc. Bail Application No. 18751 of 2024 (Pradip Kumar Jain) and No. 18606 of 2024 (Devendra Kumar Jain) — were heard together (Neutral Citation 2024:AHC:98774). The source preview states that Devendra Kumar Jain, as proprietor of Aadi Enterprises and five other non-existent firms, fraudulently availed ITC of Rs. 67.75 crores and passed on ITC of Rs. 67.46 crores, and that ITC of Rs. 45.39 crores was fraudulently availed by Pradip Kumar Jain, all without actual supply of goods through fake tax invoices.

8. Mohit Jain vs Union Of India

Bench: Madhya Pradesh High Court
Date: 19 February 2024
Sections engaged: 132(1)(b), 132(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petitioner in WP No. 23110 of 2023 before the Madhya Pradesh High Court at Indore had previously been arrested and investigated for serious IPC offences (including Sections 409 and 467 of IPC, which carry penalties up to life imprisonment) in connection with allegations of fraudulently availing Customs and IGST refunds; a charge sheet had been filed on 24 July 2023. The petitioner's counsel argued before the Court that reinitiation of investigation under CGST provisions for the same offence was not maintainable in law and violated the petitioner's fundamental rights, including the protection against double jeopardy per the source preview.

9. Sunil Mahlawat vs Central Goods And Services Tax

Bench: Punjab-Haryana High Court
Date: 10 October 2022
Sections engaged: 132(1)(i), 132(1)(b)
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (CRM-M-28562-2022) was filed under Section 439 Cr.P.C. for regular bail. The petitioner, a registered Chartered Accountant, was alleged to have shared his One Time Password with co-accused Gaurav Dhir, on the basis of which a Unique Document Identification Number was generated and used to issue a CA certificate without the petitioner's knowledge or authority; the defence further submitted that the document was signed by the co-accused and not the petitioner, and that it was the first and only instance of such sharing, per the source preview.

10. Shri Roopak Vashishth vs Union Of India Through Principal

Bench: Allahabad High Court
Date: 29 July 2022
Sections engaged: 132(1)(i), 132(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 21536 of 2022) was filed seeking bail in Case Crime No. 325 of 2020, registered under multiple sub-sections of Section 132 of the CGST Act, 2017 at PS DGGI, District Meerut, during pendency of trial. The source preview records that the applicant was alleged to be involved in GST registration of fake firms using fraudulently procured PAN cards, Aadhaar cards, and other personal information, and that a search at the registered business premises revealed those firms to be non-existent; ten firms had collectively availed ITC of Rs. 7,46,88,414/- per the source preview.

11. Paras Jain @ Rohan Jain vs Union Of India

Bench: Allahabad High Court
Date: 29 July 2022
Sections engaged: 132(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The bail application (Criminal Misc. Bail Application No. 21848 of 2022, Case Crime No. DGCI/GRU/INV/2665/2021) was filed by Paras Jain @ Rohan Jain during the pendency of trial before DGGI, GST, Ghaziabad Regional Unit, Meerut Zonal Unit. The source preview states that the DGGI complaint alleged that M/s ARJ Exim India availed fake ITC of Rs. 40.66 crores on the strength of invoices issued by non-existent firms — M/s JMJ Traders and M/s Durga Traders — which had passed on fraudulent ITC without actual supply of goods.

12. Niraj Jaidev Arya vs State Of Gujarat

Bench: Gujarat High Court
Date: 16 March 2022
Sections engaged: 132(1)(c), 132(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The application (R/Criminal Misc. Application No. 23127 of 2021) was filed under Section 439 of the Code of Criminal Procedure for regular bail in connection with the Memorandum of Arrest dated 30 November 2021 in File No. DCST/Enf.-10/Rajkot/AC-3/UT LLP/2021-22. The source preview records that the alleged offences were under the Gujarat Goods and Services Tax Act, 2017 and the CGST Act, 2017, and that the applicant is described as a designated Partner of "Utkarsh Ispat LLP", which is engaged in business activity per the source preview.

Patterns across these 12 rulings

Bail applications are the predominant procedural vehicle. Every case in this set arises from a criminal bail application (under Section 439 Cr.P.C. or Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023) filed before a High Court. This reflects the non-bailable and cognizable character of offences under the section in cases involving large-scale ITC fraud.
DGGI is the consistent prosecuting authority. Across the majority of the cases in this set — particularly those before the Allahabad High Court — the complaint or case originates from the Directorate General of GST Intelligence (DGGI), with various regional and zonal units (Meerut, Ghaziabad, Surat, Kaushambi) appearing as the registering authority. This indicates a centralised enforcement pattern for high-value CGST prosecutions.
Fake-firm and bogus-ITC allegations are the recurring substantive charge. In cases 6, 7, 10, and 11, the source previews describe a consistent factual template: creation of non-existent or shell firms, fraudulent registration using third-party identity documents, issuance of fake invoices without actual supply of goods, and large-scale ITC availment and pass-through. The amounts alleged in individual cases run from the crores to well over a hundred crores of rupees.
Section 132(1)(i) routinely appears alongside substantive CGST offence clauses. In cases 3, 6, 7, 8, 9, 10, and 11, the section is invoked together with one or more of the substantive clauses (notably 132(1)(b) and 132(1)(c)), confirming that the abetment provision is typically charged in conjunction with, not in isolation from, the primary offences. Section 70 (power to summon) also appears alongside 132(1)(i) in cases 2, 5, and 6.
Double-jeopardy and parallel-prosecution challenges have been raised. In case 8, the petitioner raised the argument that re-initiation of CGST proceedings after a prior IPC investigation and charge sheet for the same underlying conduct was not maintainable and violated fundamental rights — indicating that constitutional and procedural defences are being increasingly pressed in this category of prosecution.

How to use this compilation

This index is organised chronologically in descending order of decision date and provides the bench, date, sections engaged, and outcome direction — as available in the source corpus — for each ruling. Researchers should use the case titles, neutral citations (where available in the source previews, such as 2024:AHC:191863, 2024:AHC:98774, and 2025:AHC:171466), and court names listed here to retrieve the full text of each judgment from indiankanoon.org, the relevant High Court website, or a licensed legal database. The substantive ground paragraphs above are drawn from available text previews and should not be treated as complete summaries of the judgment's reasoning or operative direction.

Before placing any reliance on a ruling listed here, researchers should verify: (a) whether the full judgment has been uploaded and whether the available text confirms or varies the preview; (b) whether any superior court (Supreme Court or a larger bench of the same High Court) has stayed, reversed, or modified the order; and (c) whether any subsequent legislative amendment or CBDT/CBIC circular affects the statutory interpretation engaged in the ruling. Outcomes in bail matters are highly fact-specific and do not create binding precedent on the substantive questions of liability.

This compilation does not purport to be exhaustive of all High Court or Supreme Court rulings on Section 132(1)(i) of the CGST Act. New rulings are issued frequently across multiple High Courts, and the corpus is updated on a rolling basis. Researchers working on active matters should conduct a fresh search filtered by date to capture rulings issued after the publication date of this article.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 132(1)(i) CGST Act: 12 High Court Bail Rulings (2022–2026)