Accused allegedly procuring mule accounts granted bail absent direct allegations of committing online financial fraud.

The petitioners, Susanta Sahu and Jyoti Ranjan @ Rohan Pradhan, sought bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) in Berhampur Cyber P.S. Case No. 93 of 2025, corresponding to G.R. Case No. 3253 of 2025, involving alleged offences under Sections 318(2), 336(2), 340, 61(2), 111 and 3(5) of the Bharatiya Nyaya Sanhita (BNS), read with Sections 65 and 72 of the Information Technology Act.

The prosecution alleged that the petitioners procured and opened “mule” bank accounts by inducing different persons with promises of monetary benefits, collected their passbooks, ATM cards, cheque books, linked mobile numbers/SIM cards and other banking credentials, and handed them over to fraudsters for conducting online financial fraud.

The petitioners had remained in custody since 21 February 2026 and 11 March 2026, respectively, and the charge-sheet had been filed during their detention.

1. Whether the petitioners should be released on bail under Section 483 of the BNSS in view of the nature of the allegations, their alleged roles, period of custody and filing of the charge-sheet.

2. Whether bail should be granted where the principal allegation of conducting online financial fraud was not directly attributed to the petitioners and the State had not disclosed their individual financial culpability.

The Court applied Section 483 of the BNSS, which empowers the High Court to grant bail in appropriate cases.

It considered the established bail principles requiring assessment of the nature and gravity of the accusation, the specific role attributed to each accused, the period of pre-trial detention, the progress of investigation and filing of the charge-sheet, and the likelihood of the accused being tried for the principal offence.

The Court also relied on the foundational presumption that an accused is innocent until proven guilty at trial.

The alleged offences were those punishable under Sections 318(2), 336(2), 340, 61(2), 111 and 3(5) of the BNS, read with Sections 65 and 72 of the Information Technology Act.

The Court weighed the seriousness of the alleged mule-account operation against the petitioners’ particular roles and the circumstances of their detention.

Although the allegations indicated involvement in procuring bank accounts and transferring banking credentials to fraudsters, the principal allegation of carrying out the online financial fraud was not directed against the petitioners.

The Court also noted that the petitioners had undergone substantial pre-trial detention, the charge-sheet had already been submitted, and the State had failed to disclose their individual financial culpability despite being asked to do so.

Considering the manner of their implication, the roles attributed to them, and the presumption of innocence, the Court found it appropriate to grant bail without expressing any opinion on the merits of the prosecution case.

The High Court directed that Susanta Sahu and Jyoti Ranjan @ Rohan Pradhan be released on bail upon furnishing bonds of ₹50,000 each with two solvent sureties for the like amount, subject to such terms and conditions as the trial court might impose.

The BLAPLs were accordingly disposed of, and the Court directed that an urgent certified copy and a soft copy of the order be communicated to the concerned courts and jail authorities.