Banks must unfreeze accounts while securing only the disputed amount, unless a full freeze is justified.

The petitioner invoked Article 226 of the Constitution, seeking removal of a complete debit freeze on his savings account, or alternatively, a freeze limited to the disputed amount with access to the remaining balance.

He also sought disclosure of the order or communication authorising the freeze.

His counsel submitted that the case was covered by *Malcolm Murayis* and *Archana*.

The Court considered the directions in those decisions and applied them to the petitioner’s account.

1. Whether the petitioner’s bank account should remain subject to a complete freeze, or be unfrozen while only the disputed amount is secured.

2. Whether the disputed amount should be retained pending action by the competent Judicial Magistrate under the applicable law.

Article 226 empowers the High Court to grant appropriate relief where a bank-account freeze causes unjustified hardship.

Under the proportionality principles set out in *Archana v. State of Madhya Pradesh* and the SOP dated 10 April 2026, a restraint should ordinarily be limited to the suspected amount; a whole-account freeze requires justification and should not be imposed mechanically.

Banks and investigating agencies must follow the SOP’s grievance and review mechanisms.

In *Malcolm Murayis v. State Bank of India*, the Court directed that the disputed amount be kept in fixed deposits and permitted withdrawal if the competent Magistrate did not pass orders within three months.

The Court applied these decisions *mutatis mutandis*.

The Court found the principles in *Malcolm Murayis* and *Archana* applicable to the petitioner’s case.

It balanced preservation of the disputed funds for investigation against the hardship caused by freezing the entire account, and directed that the disputed amount be secured separately rather than preventing operation of the account as a whole.

Any further complaint concerning another transaction could be addressed by the Bank in accordance with law and the SOP.

The fixed deposit may be liquidated if the competent Judicial Magistrate does not pass orders within three months; any withdrawal is to be made under intimation to the Police agency.

The Bank may take lawful action concerning any other complaint in accordance with the SOP.