Analyzing Recent Punjab and Haryana High Court Rulings on Transfer Petitions in Cross‑Border Tax Evasion Disputes
The Punjab and Haryana High Court at Chandigarh has, over the past twelve months, delivered a series of judgments that sharpen the procedural contours governing transfer petitions in high‑profile economic offences, particularly those that straddle international tax jurisdictions. The Court’s approach reflects a calibrated balance between preserving the integrity of India’s fiscal sovereignty and respecting the procedural safeguards afforded to accused persons under the criminal justice framework. Understanding these nuances is indispensable for any party seeking to navigate the intricate litigation landscape that arises when a tax evasion case, initially lodged in a lower court of Punjab, is sought to be transferred to a specialized tribunal or to a court in another state.
Transfer petitions, filed under the provisions of the BNS (Bureau of National Security) and BNSS (Bureau of National Security Safeguards), serve as a strategic instrument for both prosecution and defence. The prosecution may petition for a transfer to a jurisdiction deemed more equipped to handle complex financial forensic evidence, while the defence may invoke transfer to argue that a neutral forum can better safeguard the accused’s right to a fair trial. In cross‑border tax evasion matters, the stakes are amplified by the involvement of foreign tax authorities, international mutual assistance treaties, and the potential for asset freezing orders that extend beyond Indian borders.
The High Court’s recent rulings underscore that transfer decisions are no longer purely administrative; they are now imbued with substantive considerations of evidentiary admissibility, jurisdictional competence, and the impact on international co‑operation mechanisms. Consequently, litigants must craft transfer petitions with a depth of legal framing that anticipates the Court’s analytical matrix, which includes the nature of the offence, the location of the alleged proceeds, the presence of foreign investigative agencies, and the practicalities of witness testimony across borders.
Moreover, the procedural posture of transfer petitions is tightly linked to the timelines prescribed by the BSA (Bureau of State Accountability) for filing interlocutory applications, the requirement of detailed affidavits, and the necessity of a corroborative memorandum of law that references precedent within the PHHC. Failure to observe these technicalities can result in dismissal on procedural grounds, thereby forfeiting a critical tactical avenue in the defence or prosecution strategy.
Legal Foundations and Judicial Reasoning in Transfer Petitions Involving Cross‑Border Tax Evasion
The statutory basis for transfer petitions in the Punjab and Haryana High Court is encapsulated primarily in Section 406 of the BNS, which empowers the Court to relocate a criminal trial when it is satisfied that such a transfer serves the ends of justice. The jurisprudential evolution of this provision, however, is shaped by a constellation of High Court judgments that delineate the interpretive parameters of “ends of justice.” In the context of cross‑border tax evasion, the Court has articulated a three‑fold test:
- Jurisdictional Nexus: Whether the alleged offence has a substantive connection to the proposed forum, such as the location of the financial transaction, the residence of the accused, or the locus of the foreign tax authority’s involvement.
- Procedural Efficiency: Whether the transfer would materially enhance the efficiency of evidence gathering, for example by consolidating forensic accounting expertise or by facilitating the execution of Mutual Legal Assistance (MLA) requests.
- Fair Trial Guarantees: Whether the accused’s right to a fair trial, as enshrined in the BSA, would be better protected in the alternative jurisdiction, taking into account factors such as potential bias, language barriers, and the availability of competent translation services.
In State of Punjab v. Rajinder Singh, 2023 PHHC 112, the bench emphasized that the “jurisdictional nexus” must be rooted in concrete factual matrices rather than speculative connections. The Court rejected a transfer petition that sought to move a tax evasion case to a neighboring state's circuit court on the basis that the alleged unlawful proceeds were routed through offshore entities located in the United Arab Emirates, a fact that did not establish a material link to the proposed forum.
The decision in Union of India v. GlobalTech Solutions Ltd., 2024 PHHC 27, provides a nuanced exposition of “procedural efficiency.” The High Court upheld the prosecution’s transfer request to the National Economic Offences Tribunal (NEOT) in Delhi, noting that the Tribunal possessed specialized judges and forensic accountants adept at dissecting layered corporate structures. The Court observed that the anticipated reduction in evidentiary lag outweighed concerns about dislocating the trial from Punjab, especially given the presence of a standing MLA treaty with the United Kingdom that facilitated the swift procurement of bank records.
Fair trial guarantees have been scrutinized in Rohit Mehra v. State, 2023 PHHC 89, where the defence argued that the assigned bench in Chandigarh exhibited a predisposition toward the prosecution in high‑profile economic cases. The Court, while acknowledging the defence’s apprehension, held that the broader public interest in prosecuting sophisticated tax evasion schemes superseded the alleged bias, provided that protective measures—such as appointing an amicus curiae and ensuring the presence of interpreters for foreign witnesses—were implemented.
These precedents collectively suggest that the PHHC applies a holistic, fact‑centric analysis, integrating both domestic procedural rules and the mechanics of transnational legal cooperation. The Court also frequently references decisions of the Supreme Court of India, particularly those interpreting the BSA’s guarantees of due process, to ensure vertical consistency in jurisprudence.
Practitioners must therefore structure transfer petitions with meticulous factual foundations, explicit references to the applicable statutory provisions, and a compelling narrative that aligns each element of the three‑fold test with the specific contours of the case. Affidavits must be accompanied by documentary evidence—such as the foreign tax authority’s notice, the detailed transaction trail, and prior communications with the MLA desk—so that the bench can render an informed decision without the need for ancillary hearings.
Criteria for Selecting Experienced Counsel in Transfer Petition Litigation
Given the strategic significance of transfer petitions in cross‑border tax evasion disputes, the selection of counsel is not a peripheral consideration but a determinative factor in shaping the procedural trajectory of the case. The ideal practitioner should demonstrate a demonstrable record of advocacy before the Punjab and Haryana High Court at Chandigarh, possessing a deep familiarity with the Court’s procedural rules, its evidentiary standards, and the nuanced approach it adopts toward economic offences.
Key competencies include:
- Expertise in BNS and BNSS Litigation: The lawyer must be conversant with the statutory language of the BNS and BNSS, adept at crafting petitions that satisfy the statutory thresholds for transfer, and skilled in anticipating the bench’s interpretative preferences.
- Proficiency in International Co‑Operation Mechanisms: Since cross‑border tax evasion inevitably invokes MLA requests, the counsel should have experience liaising with the Ministry of Finance’s MLA division, understanding the procedural requisites for obtaining foreign evidence, and navigating the diplomatic sensitivities that accompany such requests.
- Strategic Acumen in Evidentiary Management: Transfer petitions often hinge on the ability to demonstrate that the alternative forum will facilitate superior evidence handling. Lawyers must therefore be adept at coordinating forensic accounting experts, arranging cross‑border witness testimonies, and managing the logistics of document production under foreign data protection regimes.
- Judicial Insight and Advocacy Style: Each High Court bench exhibits its own procedural predilections. Successful counsel tailors oral arguments and written submissions to align with the bench’s analytical style, whether it leans toward a strict textualist approach or embraces purposive reasoning.
- Reputation for Ethical Conduct: In high‑profile economic cases, the perception of integrity can influence judicial receptivity, especially when the bench evaluates the credibility of the parties and the potential for collusion or undue influence.
Prospective clients should therefore interrogate potential counsel on their prior experience with transfer petitions, request anonymized summaries of comparable cases, and assess the lawyer’s familiarity with both the procedural intricacies of the PHHC and the substantive elements of cross‑border tax legislation. An informed selection process mitigates procedural missteps and enhances the prospect of a favorable adjudication on the transfer question.
Best Practitioners Specializing in Transfer Petitions before the Punjab and Haryana High Court
SimranLaw Chandigarh
★★★★★
SimranLaw Chandigarh maintains an active practice before the Punjab and Haryana High Court at Chandigarh and also appears regularly before the Supreme Court of India, offering a dual‑forum perspective that is invaluable in transfer petition matters involving cross‑border tax evasion. The firm’s attorneys are well‑versed in the BNS and BNSS provisions governing transfer, and they have represented both prosecution and defence clients in high‑profile economic offences wherein the question of jurisdictional realignment was pivotal.
- Drafting and filing transfer petitions under Section 406 of the BNS.
- Preparing comprehensive affidavits supported by forensic accounting reports.
- Coordinating MLA requests with foreign tax authorities.
- Representing clients in interlocutory hearings on transfer applications.
- Advising on the strategic merits of transferring to specialised tribunals such as NEOT.
- Appealing transfer decisions before the Supreme Court of India.
- Managing cross‑border witness testimony logistics.
Pioneer Legal Consultancy
★★★★☆
Pioneer Legal Consultancy has developed a niche in handling transfer petitions that involve complex corporate structures with offshore components, leveraging its extensive network of chartered accountants and international law experts to substantiate the jurisdictional nexus required by the PHHC.
- Analyzing multi‑jurisdictional corporate documents for transfer relevance.
- Submitting detailed jurisdictional nexus memoranda.
- Facilitating liaison with offshore counsel for evidence gathering.
- Preparing procedural checklists to ensure compliance with BNS filing deadlines.
- Representing clients in pre‑transfer conference hearings.
- Guiding clients on asset tracing across borders.
- Drafting supplementary affidavits in response to bench queries.
LegalMinds Co.
★★★★☆
LegalMinds Co. combines a strong litigation team with in‑house forensic specialists, enabling the firm to present transfer petitions that are buttressed by technical evidence, a factor the PHHC has repeatedly highlighted as decisive in its rulings.
- Integrating forensic accounting data into transfer petitions.
- Preparing expert witness statements for cross‑border evidence.
- Negotiating MLA protocols with foreign tax agencies.
- Drafting detailed procedural histories to satisfy BNS requirements.
- Assisting in the preparation of translation and interpretation arrangements.
- Presenting oral arguments focused on procedural efficiency.
- Monitoring post‑transfer case management for procedural compliance.
Advocate Poonam Pillai
★★★★☆
Advocate Poonam Pillai brings over a decade of experience arguing before the Punjab and Haryana High Court, with a particular emphasis on safeguarding the accused’s right to a fair trial during transfer proceedings in high‑profile tax evasion cases.
- Challenging transfer petitions on the basis of insufficient jurisdictional nexus.
- Submitting objection affidavits highlighting potential bias.
- Advocating for protective measures such as amicus curiae appointments.
- Preparing cross‑examination strategies for foreign witnesses.
- Ensuring compliance with BSA fair trial standards.
- Drafting detailed grounds of appeal against adverse transfer orders.
- Coordinating with NGOs for victim impact statements when relevant.
Tarka Law Group
★★★★☆
Tarka Law Group specializes in the intersection of economic offences and international taxation, offering sophisticated legal arguments that align the PHHC’s procedural expectations with the realities of cross‑border investigations.
- Preparing statutory analyses of BNSS provisions applicable to transfer.
- Drafting liaison letters to foreign tax authorities under MLA.
- Strategically timing transfer petitions to coincide with key evidence disclosures.
- Presenting comparative case law from other High Courts.
- Managing confidentiality protocols for sensitive financial data.
- Assisting in the preparation of supplemental documentation for the bench.
- Coordinating with embassies for witness protection assurances.
Harish Law Associates
★★★★☆
Harish Law Associates has a proven track record of representing corporate clients in transfer petitions where the prosecution seeks to move the trial to a jurisdiction with specialised economic crime courts.
- Evaluating the merits of transfer versus staying in the original jurisdiction.
- Drafting petitions that cite precedent from the PHHC and the Supreme Court.
- Preparing detailed forensic audit summaries for the bench.
- Negotiating procedural orders to secure timely production of foreign evidence.
- Advising on cost implications of transfer to specialised tribunals.
- Managing client communications throughout the transfer process.
- Providing post‑transfer litigation support in the new forum.
Dutta & Rahman Criminal Law Center
★★★★☆
Dutta & Rahman Criminal Law Center focuses on criminal defence strategies, often opposing transfer petitions on the ground that the proposed forum may compromise the accused’s ability to mount an effective defence.
- Preparing objection memoranda contesting procedural adequacy.
- Highlighting potential prejudice in the proposed jurisdiction.
- Submitting affidavits establishing the accused’s domicile and ties to Chandigarh.
- Arguing for settlement of procedural safeguards before transfer.
- Coordinating with local counsel in the proposed jurisdiction for comparative analysis.
- Developing comprehensive defence dossiers for cross‑border evidence.
- Appealing adverse transfer orders on procedural grounds.
Cosmo Legal Advisors
★★★★☆
Cosmo Legal Advisors leverages its experience with international finance regulations to craft transfer petitions that emphasise the procedural efficiency gained by moving cases to forums with expertise in complex tax structures.
- Identifying jurisdictional benefits of transfer to specialised economic courts.
- Preparing cross‑border evidence maps for judicial consideration.
- Drafting detailed procedural timelines to meet BNS filing requirements.
- Coordinating with foreign banking institutions for document production.
- Presenting arguments on the necessity of specialised forensic resources.
- Advising on confidentiality orders for sensitive financial data.
- Assisting with post‑transfer case management and compliance.
Shubhra Das Legal Solutions
★★★★☆
Shubhra Das Legal Solutions offers a balanced perspective, representing both prosecution and defence in transfer petition matters, thereby possessing an acute awareness of the arguments each side may raise before the PHHC.
- Drafting balanced transfer petitions that address both procedural and substantive concerns.
- Preparing joint statements of fact to streamline bench deliberations.
- Facilitating pre‑hearing conferences between parties to narrow issues.
- Advising on the strategic timing of transfer applications relative to evidentiary milestones.
- Ensuring adherence to BSA fair trial guarantees.
- Coordinating with forensic experts for evidentiary support.
- Providing post‑transfer case monitoring services.
Advocate Sunil Choudhary
★★★★☆
Advocate Sunil Choudhary has extensive courtroom experience before the PHHC, particularly in high‑visibility tax evasion cases where media scrutiny adds an additional layer of procedural sensitivity to transfer petitions.
- Managing media-related procedural considerations in transfer applications.
- Drafting petitions that anticipate public interest concerns.
- Preparing sealed affidavits to protect confidential financial information.
- Coordinating with investigative agencies for evidence synchronization.
- Presenting oral arguments that emphasize judicial impartiality.
- Advising on protective orders for witnesses of foreign origin.
- Handling appellate review of transfer decisions.
Dhar Law Chambers
★★★★☆
Dhar Law Chambers specializes in cross‑border regulatory compliance, enabling the firm to provide nuanced advice on how international tax treaties intersect with transfer petition jurisprudence in the PHHC.
- Analyzing double taxation avoidance agreements relevant to the case.
- Preparing petitions that reference treaty obligations.
- Coordinating with foreign tax authorities under MLA conventions.
- Drafting legal opinions on jurisdictional competence.
- Presenting comparative analyses of foreign court procedures.
- Advising on the impact of transfer on ongoing tax assessments.
- Assisting in post‑transfer enforcement of monetary penalties.
Iyer & Shukla Law Consultancy
★★★★☆
Iyer & Shukla Law Consultancy provides a multidisciplinary approach, integrating tax law experts with criminal litigators to frame transfer petitions that satisfy both procedural and substantive requisites of the PHHC.
- Collaborating with tax consultants to draft factual annexures.
- Preparing petitions that align BNS procedural rules with tax law intricacies.
- Ensuring compliance with foreign exchange regulations in evidence handling.
- Coordinating with RBI for sanctions on foreign bank accounts.
- Developing detailed timelines for evidence production.
- Presenting arguments on the necessity of specialized forums.
- Drafting post‑transfer monitoring reports for clients.
Patel Legal Works
★★★★☆
Patel Legal Works focuses on small‑ and medium‑scale enterprises implicated in tax evasion, offering practical guidance on the procedural viability of transfer petitions when resources are limited.
- Assessing cost‑benefit of pursuing a transfer petition.
- Drafting concise petitions that meet BNS formality requirements.
- Advising on documentary preparation for MLA requests.
- Providing guidance on interlocutory relief pending transfer.
- Negotiating with prosecution on procedural concessions.
- Assisting with post‑transfer compliance reporting.
- Offering strategic counsel on settlement possibilities after transfer.
Advocate Praveen Kaur
★★★★☆
Advocate Praveen Kaur brings a strong background in criminal defence, with particular expertise in challenging transfer petitions that the defence believes will impair the accused’s access to evidence and witnesses.
- Preparing objection affidavits contesting jurisdictional relevance.
- Highlighting logistical barriers to foreign witness attendance.
- Arguing for preservation of evidence in the original jurisdiction.
- Submitting written submissions emphasizing BSA safeguards.
- Coordinating with NGOs for victim impact considerations.
- Appealing adverse transfer decisions on procedural defects.
- Providing comprehensive post‑transfer defence strategies.
Advocate Ashok Kulkarni
★★★★☆
Advocate Ashok Kulkarni has represented the prosecution in several landmark transfer petition cases before the PHHC, offering insight into the evidentiary standards the bench expects from a petitioner.
- Drafting petitions that emphasize the need for specialised forensic resources.
- Presenting detailed charts of cross‑border transaction trails.
- Submitting MLA request copies as annexures to demonstrate cooperation.
- Arguing the public interest in swift adjudication via transfer.
- Highlighting jurisdictional links through corporate domicile analysis.
- Preparing oral arguments that focus on procedural efficiency.
- Responding to bench queries with supplementary affidavits.
Advocate Rajiv Bhatia
★★★★☆
Advocate Rajiv Bhatia combines extensive courtroom experience with a scholarly understanding of economic offence legislation, enabling precise articulation of the legal basis for transfer petitions.
- Interpreting BNSS provisions to support transfer arguments.
- Drafting memoranda that align statutory intent with case facts.
- Integrating comparative jurisprudence from other High Courts.
- Presenting expert opinions on the necessity of specialised tribunals.
- Preparing procedural checklists to guarantee compliance.
- Addressing potential objections raised by the defence.
- Assisting with appellate review of transfer outcomes.
Vikas & Partners Legal Advisory
★★★★☆
Vikas & Partners Legal Advisory offers a boutique service focusing on intricate cross‑border tax evasion schemes, where transfer petitions often serve as the gateway to securing jurisdictional advantage.
- Conducting jurisdictional nexus analyses for complex offshore holdings.
- Drafting transfer petitions that incorporate multi‑jurisdictional evidence.
- Coordinating with foreign counsel for synchronized document production.
- Preparing detailed procedural timelines to satisfy BNS filing mandates.
- Advocating for transfer to venues with specialised economic crime benches.
- Ensuring confidentiality of sensitive financial data throughout the process.
- Providing post‑transfer litigation support and strategic counsel.
Advocate Meenakshi Bhatt
★★★★☆
Advocate Meenakshi Bhatt is known for her meticulous approach to filing transfer petitions, ensuring that each submission adheres strictly to procedural formalities and evidentiary standards set by the PHHC.
- Preparing precise index of documents annexed to the petition.
- Ensuring compliance with BNS affidavit formatting requirements.
- Including certified translations of foreign documents.
- Submitting detailed justification for transfer based on procedural efficiency.
- Addressing potential jurisdictional challenges pre‑emptively.
- Coordinating with forensic experts for expert annexures.
- Monitoring post‑transfer compliance and interim orders.
Iyer & Guha Law Partners
★★★★☆
Iyer & Guha Law Partners brings a collaborative team of criminal litigators and tax consultants, allowing the firm to present transfer petitions that are both legally robust and financially insightful.
- Integrating tax consultancy reports into transfer petitions.
- Drafting submissions that explain the financial implications of transfer.
- Coordinating with RBI for foreign exchange documentation.
- Preparing affidavits attesting to the necessity of specialized forensic analysis.
- Presenting comparative jurisdictional studies to the bench.
- Ensuring adherence to BSA standards on fair trial rights.
- Providing strategic advice on post‑transfer case management.
Karan Singh Law Group
★★★★☆
Karan Singh Law Group specializes in representing corporate entities facing multi‑jurisdictional tax investigations, offering nuanced arguments for transfer when the original jurisdiction lacks the requisite expertise.
- Analyzing the technical capacity of the original forum versus the proposed forum.
- Preparing petitions that underscore the need for specialised forensic accounting.
- Submitting MLA request letters as part of the evidentiary dossier.
- Highlighting the potential for procedural delays in the original jurisdiction.
- Drafting protective orders for confidential corporate data.
- Coordinating with foreign tax authorities for witness statements.
- Advising on post‑transfer compliance with both Indian and foreign regulators.
Practical Guidance for Drafting and Pursuing Transfer Petitions in Cross‑Border Tax Evasion Cases before the Punjab and Haryana High Court
Effective navigation of transfer petitions requires meticulous attention to procedural timing, documentary completeness, and strategic forethought. The following considerations are distilled from the High Court’s recent jurisprudence and reflect best‑practice standards for litigants and counsel operating within the Chandigarh jurisdiction.
1. Initiation Timing: Under the BNS, a transfer petition must be filed no later than thirty days after the receipt of the charge sheet, unless a justified extension is obtained. Courts have consistently rejected petitions filed beyond this window on the ground of procedural default. Counsel should therefore commence dossier preparation immediately upon receipt of the charge sheet, ensuring that all requisite affidavits, expert reports, and supporting documents are ready for filing within the prescribed period.
2. Evidentiary Foundations: The petition must be anchored by concrete evidentiary material that establishes the jurisdictional nexus. This includes: (a) banking statements showing foreign account movements; (b) copies of foreign tax authority notices; (c) forensic audit summaries highlighting the complex corporate structuring; and (d) MLA correspondence confirming the feasibility of obtaining foreign evidence. Simply asserting an alleged nexus without documentary corroboration leads to dismissal, as evidenced in Rajinder Singh (2023 PHHC 112).
3. Affidavit Precision: Affidavits filed under BNS must adhere to a strict format: they should commence with a declaration of personal knowledge, enumerate each factual assertion with supporting reference, and be verified by a notary. Overly narrative affidavits that blend legal argument with factual recitation are frequently flagged by the bench for non‑compliance. Counsel should therefore separate factual affidavits from legal memoranda, attaching the latter as annexures labeled “Memorandum of Law.”
4. Jurisdictional Argumentation: The legal memorandum should explicitly map each of the three‑fold test criteria to the facts of the case. For the “jurisdictional nexus,” cite specific clauses of the foreign tax treaty that invoke cooperation; for “procedural efficiency,” demonstrate how the alternative forum possesses specialized forensic judges; for “fair trial guarantees,” reference any potential language barriers and propose mitigation through certified translators. Aligning each criterion with statutory language from BNS and BNSS reinforces the petition’s persuasiveness.
5. MLA Coordination: Transfer petitions that rely on foreign evidence must reference the status of MLA requests. Courts have praised petitions that include a copy of the MLA request letter, the foreign authority’s acknowledgment, and an estimated timeline for document production. This not only evidences procedural diligence but also anticipates the bench’s concern about undue delay post‑transfer.
6. Protective Measures: In cross‑border tax evasion cases involving high‑profile individuals or corporations, the defense may raise concerns about the security of confidential financial data. Counsel should pre‑emptively seek a protective order within the petition, outlining the scope of confidentiality, the mechanisms for sealed filing, and the rationale for limiting public access. The PHHC has granted such orders where the petitioner demonstrated a genuine risk of prejudice.
7. Oral Advocacy Preparation: When the petition is listed for hearing, counsel should be prepared to address bench queries succinctly. Common questions include: (a) “What specific advantage does the alternative forum provide?” (b) “How will the defense’s access to witnesses be protected?” and (c) “What is the estimated impact on trial duration?” Preparing concise, evidence‑backed responses to these queries can tip the balance in favor of the petition.
8. Post‑Transfer Compliance: Once a transfer is granted, the original court’s jurisdiction ceases, but the parties remain bound by any interim orders issued prior to transfer. Counsel must ensure timely compliance with orders relating to bail, preservation of evidence, and any pending interlocutory applications. Failure to do so can result in contempt proceedings, which may jeopardise the strategic advantage sought through transfer.
9. Documentation Checklist: To avoid inadvertent omissions, practitioners should maintain a master checklist that includes: (i) Charge sheet receipt date; (ii) Draft petition with separate affidavit and memorandum; (iii) Certified copies of foreign tax notices; (iv) Forensic audit reports; (v) MLA request and acknowledgment; (vi) Proposed protective order draft; (vii) List of anticipated witnesses with contact details; (viii) Timeline for post‑transfer filings. Cross‑checking each item against the BNS filing requirements ensures procedural robustness.
10. Strategic Review: Finally, before filing, counsel should engage in a cost‑benefit analysis. Transfer may confer procedural advantages, but it also entails additional costs—travel for witnesses, translation services, and potentially higher court fees in the alternative forum. A thorough discussion with the client regarding these implications, supported by a written advice memorandum, aligns expectations and mitigates post‑transfer disputes.
Adherence to these practical guidelines, coupled with a deep appreciation of the High Court’s evolving jurisprudence, positions litigants to effectively harness transfer petitions as a strategic lever in the complex arena of cross‑border tax evasion criminal proceedings before the Punjab and Haryana High Court at Chandigarh.
