Bail Denied to Mule Account Holder in Cyber Fraud Case Involving Multiple Inter-State Transactions

The applicant, Ashish Kumar, filed his first bail application following his arrest on 29.01.2026 in connection with Crime No. 358/2025.

The prosecution alleged that the applicant’s bank account at the Bank of Maharashtra, Baikunthpur, was utilized as a "Mule Account" for cyber fraud.

Investigations following a cyber cell report revealed that Rs. 93,001/-, linked to fraudulent activities across multiple states (Maharashtra and Madhya Pradesh), was deposited into his account.

Total credits in the account amounted to Rs. 1,05,165/-, with nearly the entire amount subsequently debited/withdrawn.

The applicant argued he was falsely implicated, had no direct role in the fraud, and that the charge-sheet had already been filed.

1. Whether the applicant is entitled to regular bail under Section 483 of the Bhartiya Nagrik Suraksha Sanhita, 2023, considering the allegations of participating in an organized cyber fraud network as a mule account holder.

The Court considered Section 483 of the Bhartiya Nagrik Suraksha Sanhita (BNSS), 2023 (corresponding to Section 439 of the CrPC) regarding the High Court's power to grant regular bail.

The substantive charges were framed under the Bharatiya Nyaya Sanhita (BNS), 2023: Section 111 (Organized crime), Section 317(2) & (5) (Dealing with stolen property/dishonest misappropriation), and Section 371(4) (Habitual dealing in stolen property).

The court's discretion was guided by the gravity of the offense and the nature of the evidence indicating the applicant was "instrumental" in deceiving the public.

The Court scrutinized the additional affidavit filed by the Investigating Officer, which detailed the transactional trail of the applicant's bank account.

The analysis showed that the account was opened shortly before the transactions (28.02.2025) and was used to receive deposits from cyber fraud victims in Mumbai, Katni, and Chhatarpur via the National Cyber Crime Reporting Coordination Portal.

The Court noted that the rapid debiting of the fraudulent funds—leaving a negligible balance of Rs. 856.15—demonstrated that the applicant acted as a conduit for a criminal gang.

Despite the defense's claim of no direct evidence of online cheating, the Court found the applicant's role as a "mule" provided sufficient evidence of dishonest intent and participation in organized crime.

The first bail application was rejected.

The trial court was granted liberty to proceed with and conclude the trial expeditiously.