Delhi High Court

Anticipatory bail refused in cyber-fraud cases where custodial interrogation is essential to unearth transnational conspiracies.

Akash Kumar vs Central Bureau Of Investigation

Delhi High CourtJUDGMENT: May 04, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner sought anticipatory bail regarding FIR No. RC2212025E0005, registered by the CBI for a nation-wide investment fraud involving a fake trading app named ‘Anisha’

Source reference: p. 1-2

The syndicate allegedly defrauded investors of approximately Rs. 150 crores using over 650 SIM cards and 41 bank accounts managed via common IP addresses

Source reference: p. 2

Investigation revealed that Rs. 2.77 crores was credited to a 'Falcon Resealing Enterprises' account, which, though in another's name, was allegedly managed by the Petitioner using fake documents

Source reference: p. 2

Technical analysis geo-located the account's access to the Petitioner’s residence and linked his personal mobile number to the same IMEI used to operate the suspect account

Source reference: p. 3-4

Sessions Court dismissed his bail application on July 14, 2025

Source reference: p. 3
02

Issues

1. Whether the Petitioner is entitled to the protection of anticipatory bail given the allegations of a large-scale organized cyber-financial fraud and his technical nexus to the crime

Source reference: p. 5-6

2. Whether custodial interrogation is necessary to unearth the conspiracy and the source of crypto-currency transactions

Source reference: p. 3, 6
03

Law Applied

The court applied Sections 61(2), 318(4), 340(2), and 336(3) of the Bharatiya Nyaya Sanhita (BNS), 2023, along with Sections 66C and 66D of the Information Technology Act, 2000

Source reference: p. 1

It relied on the principle from State of Rajasthan v. Balchand regarding bail

Source reference: p. 5

Crucially, the court cited State (Represented by CBI) v. Anil Sharma, emphasizing that custodial interrogation is "qualitatively more elicitation oriented" than questioning a suspect protected by a pre-arrest bail order

Source reference: p. 5

It further applied P. Chidambaram v. Directorate of Enforcement, holding that the court must balance individual liberty under Article 21 with the state's right to effective interrogation in economic offences impacting society

Source reference: p. 5
04

Reasoning

The court reasoned that the gravity of the organized cyber-crime and its massive societal impact outweighed the Petitioner's plea for liberty

Source reference: p. 5

The analysis of CDRs and IMEIs established a "technological and physical nexus" between the Petitioner and the fraudulent bank accounts

Source reference: p. 4

Furthermore, the court noted that the Petitioner had received 6,984 USDT in crypto-currency and was suspected of communicating with perpetrators in China and destroying his actual mobile handsets

Source reference: p. 3

The court found that because the Petitioner might have eluded the investigation if shielded by a bail order, his custodial interrogation was imperative to scrutinize his international connections and unearth the conspiracy

Source reference: p. 3, 5-6
05

Holding

The Court dismissed the anticipatory bail application

It held that in serious economic offences and cyber-crimes, pre-arrest protection cannot be granted when custodial interrogation is essential to reach the truth

Source reference: p. 6

The court found no compelling reason to enlarge the Petitioner on bail, citing the need to investigate the crypto-currency trail and foreign links

Source reference: p. 6

All pending applications were disposed of accordingly

Source reference: p. 6
Delhi High Court

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Akash KumarvsCentral Bureau Of Investigation

Delhi High Court · May 04, 2026

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