Chhattisgarh High Court

Bail denied where applicant facilitated organized cyber fraud by providing mule bank accounts for monetary gain.

JAIPRAKASH DHIRHE vs THE STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 24, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant, Jaiprakash Dhirhe, filed a first bail application following his arrest on April 5, 2025, in connection with a large-scale cyber fraud racket

Source reference: para. 1, 6

Investigation by the Indian Cyber Cell revealed that multiple victims were defrauded via transactions routed through various bank accounts

Source reference: para. 2

The applicant allegedly provided his UCO Bank account, ATM card, and SIM card to co-accused Suraj Diwan in exchange for a monthly payment of ₹15,000

Source reference: para. 6

Bank statements indicated that approximately ₹17,26,870/- obtained through fraud was transacted through the applicant’s account, which was linked to 13 distinct complaints

Source reference: para. 6

Total credits in the account between September and October 2024 exceeded ₹51 lakhs

Source reference: para. 6

The applicant sought bail on grounds of innocence, lack of criminal antecedents, and the failure of witnesses to identify him during court depositions

Source reference: para. 3
02

Issues

Whether the applicant is entitled to regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, considering the nature of the allegations and the evidence of his involvement in a cyber fraud syndicate

Source reference: para. 1, 7
03

Law Applied

Court considered Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, regarding the grant of regular bail

Source reference: para. 1

Substantive charges were registered under Sections 317(4) (stolen property), 318(2) (cheating), and 61(2)(A) (criminal conspiracy) of the Bharatiya Nyaya Sanhita (BNS), 2023, along with Section 66(D) (punishment for cheating by personation by using computer resource) of the Information Technology Act, 2000

Source reference: para. 1, 8

The Court applied the principles of gravity of the offence, the organized nature of the crime, the potential for tampering with evidence, and the doctrine of parity in bail matters

Source reference: para. 4, 7
04

Reasoning

The Court analyzed the severity of the organized cyber fraud network and the applicant's specific role as a "mule account" provider.

Source reference: no citation

While the applicant argued that prosecution witnesses could not identify him, the Court highlighted the documentary evidence, specifically bank records and transaction details, which established a direct financial trail and a nexus between the applicant and the crime

Source reference: para. 4, 7

The Court noted that the applicant’s extra-judicial confession, admitting to handing over his account and SIM card for monetary inducement, strengthened the prosecution's prima facie case

Source reference: para. 6, 7

The Court observed that the bail application of a co-accused, Saurabh Sahu, had already been rejected; therefore, the applicant could not claim relief on the ground of parity

Source reference: para. 4, 7

The organized nature of the crime and its wide-reaching impact on victims across multiple states weighed heavily against the exercise of judicial discretion for bail

Source reference: para. 7
05

Holding

The Court answered the issue in the negative and rejected the bail application

It held that the applicant was actively involved in facilitating a cyber fraud racket by providing essential infrastructure (bank accounts and SIM cards) for siphoning proceeds of crime

Source reference: para. 7

The High Court directed the trial court to proceed with and conclude the trial expeditiously and the application was dismissed

Source reference: para. 8, 9
Chhattisgarh High Court

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JAIPRAKASH DHIRHEvsTHE STATE OF CHHATTISGARH

Chhattisgarh High Court · April 24, 2026

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