Bail Denied for Beneficiary in Massive Cyber-Fraud Scam Involving Organized Mule Account Syndicates

The applicant, Laxminarayan Patel, filed a first bail application under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) after being arrested in connection with Crime No. 763/2025.

The prosecution alleged that the applicant opened and operated a "mule" bank account under the name "Laxmi Traders" and "Mahalaxmi Traders" at IDBI Bank.

This account was allegedly used by a cybercrime syndicate for fraudulent online trading and cricket betting transactions amounting to approximately Rs. 6.80 crores between June and July 2025.

The investigation linked the account to 61 victim complaints across various states.

The applicant contended he was falsely implicated, had filed a prior complaint regarding suspicious activity, and that a co-accused had allured him into opening the account; he has been in custody since September 20, 2025.

1. Whether the applicant is entitled to the grant of regular bail under Section 483 of the BNSS considering the nature of the allegations and his period of incarceration.

The Court considered Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), which governs the power of the High Court to grant bail.

Sections 317(4) (stolen property), 318(4) (cheating), and 61(2)(a) (criminal conspiracy) of the Bharatiya Nyaya Sanhita (BNS), and Section 66D of the Information Technology Act (punishment for personation using computer resource).

The court relied on the principle of parity in reverse, noting that the bail application of a similarly situated co-accused (Anil Kurre) had been previously rejected.

The Court analyzed the gravity of the offense, highlighting that the applicant was not merely a passive account holder but a beneficiary who received commissions for facilitating an organized cybercrime syndicate.

The Court emphasized the massive scale of the fraud—Rs. 6.80 crores—and the impact on 61 victims nationwide.

Although the applicant argued that his case differed from the co-accused whose bail was rejected, the Court found that the digital and banking evidence directly linked him to the routing and withdrawal of fraudulent funds.

The Court concluded that the organized nature of the crime and the applicant's role as a facilitator for a "mule account" outweighed the factors favoring bail, such as the filing of the charge sheet or the duration of his pretrial detention.

The High Court of Chhattisgarh rejected the bail application of Laxminarayan Patel and directed the office to communicate the order to the trial court for information.