Bail is denied where an accused knowingly facilitates cyber-fraud proceeds through a mule bank account.

The petitioner sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in FIR No. 109 dated 8 September 2025, registered at Police Station Cyber Crime, Chandigarh, for offences under Sections 318(4), 351(2) and 61(2) of the Bharatiya Nyaya Sanhita, 2023; Sections 112(2) and 317(2) were subsequently added.

The FIR originated from a complaint alleging that the complainant’s bank account was used for receiving and withdrawing money connected with cyber frauds.

During investigation, the police found that ₹8.78 lakh, allegedly representing proceeds of cyber fraud, had been transferred from an account operated by co-accused Gaurav Thakur into the petitioner’s bank account.

The amount was withdrawn on the same day, and the petitioner allegedly permitted his account to be used as a mule account in exchange for ₹4,000.

The petitioner was arrested on 18 January 2026, and the investigation had concluded by the time of consideration of the bail petition.

Whether the petitioner, accused of knowingly permitting his bank account to be used for routing and withdrawing alleged proceeds of cyber fraud, was entitled to regular bail under Section 483 of the BNSS, 2023?

Whether the petitioner’s alleged limited role, receipt of only ₹4,000 as commission, absence from the original FIR, and completion of investigation constituted compelling grounds for granting bail?

The Court applied Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, governing the High Court’s power to grant regular bail.

The alleged offences were considered under Sections 318(4), 351(2), 61(2), 112(2) and 317(2) of the Bharatiya Nyaya Sanhita, 2023, concerning the alleged cheating, criminal intimidation, organised criminal activity and handling or use of proceeds connected with the offences.

The Court reiterated that bail requires assessment of the gravity and specific nature of the allegations, the accused’s role, the supporting material collected during investigation, and the broader impact of the alleged offence.

It held that organised cyber fraud and the provision of banking channels for routing illicit funds are serious economic offences warranting a strict approach at the stage of bail.

The Court found that the petitioner’s role was not based merely on his presence or association with the co-accused; rather, the investigation specifically attributed to him the provision and use of his bank account for receiving and withdrawing ₹8.78 lakh allegedly derived from fraudulent transactions.

The supporting documents collected during investigation indicated that three fraudulent deposits were credited to his account and withdrawn on the same day, and that he had disclosed receiving ₹4,000 for permitting its use.

The Court rejected the arguments that the petitioner was not named in the FIR, had been induced by the co-accused, or had benefited only to a limited extent, observing that his role as a mule-account holder had clearly emerged during investigation.

Given that the alleged conduct formed part of an organised cyber-fraud network and facilitated the routing of proceeds of crime, the completion of investigation and the petitioner’s claimed limited financial benefit did not outweigh the seriousness of the allegations.

The petition was accordingly dismissed.

The Court clarified that its observations were confined to the determination of bail and would not prejudice the merits of the trial.

Any pending application was rendered infructuous.