Chhattisgarh High Court

Facilitating organized cyber fraud through mule bank accounts disentitles the accused to regular bail.

AJAY KUMAR vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: April 09, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant was arrested on December 21, 2025, in connection with Crime No. 452/2025 for alleged cyber fraud operations

Source reference: para 3, 6.10

Following a report from the "Sammanvay" Cyber Crime Reporting Portal, authorities identified 17 mule bank accounts at DCB Bank, Raipur, used to funnel proceeds from cybercrimes

Source reference: para 2, 6.5

Investigation revealed that one specific account (No. 21214700000435) registered to one Gul Hamza was used for illegal transactions totaling ₹1,29,88,840/-

Source reference: para 6.6, 8

Gul Hamza’s memorandum statement alleged he handed the banking kit to the applicant, who admitted to facilitating the account opening and selling the kit to a co-accused, Prakash Singh, in exchange for monetary consideration

Source reference: para 6.8, 9

The applicant sought regular bail under Section 483 of the Bhartiya Nagrik Suraksha Sanhita (BNSS), 2023

Source reference: para 1
02

Issues

Whether the applicant is entitled to regular bail under Section 483 of the BNSS, given his alleged role as an "account broker" in an organized cyber fraud syndicate

Source reference: para 7, 10
03

Law Applied

Section 483 of the Bhartiya Nagrik Suraksha Sanhita (BNSS), 2023, regarding the grant of regular bail

Source reference: para 1

Offences under the Bharatiya Nyaya Sanhita (BNS), 2023, specifically Section 111 (Organized Crime), Section 3(5) (Joint Liability/Common Intention), and Section 317(2), (4), and (5) (relating to stolen property and receiving proceeds of crime)

Source reference: para 1, 11

The principle that the gravity of the offence, the organized nature of the crime, and the potential for tampering with evidence are primary considerations in bail adjudications

Source reference: para 10
04

Reasoning

The Court found that the material collected during the investigation established a prima facie case of a "deep-rooted, structured, and profit-oriented criminal conspiracy"

Source reference: para 4, 7

The Court highlighted that the applicant played an "indispensable and conscious role" by acting as an intermediary who procured and sold mule accounts used to launder massive sums exceeding ₹1.29 crores

Source reference: para 4, 8

The Court rejected the applicant's plea of innocence, noting that the memorandum statements of the account holder directly linked the applicant to the procurement of the fraudulent banking kits

Source reference: para 9

The organized modus operandi adopted by the accused posed a significant risk to society and that releasing the applicant could lead to the tampering of evidence or the influence of witnesses

Source reference: para 10

The Court emphasized that the magnitude of the fraud and the applicant's active facilitation of illegal financial transactions outweighed the duration of his incarceration

Source reference: para 10, 11
05

Holding

The High Court rejected the first bail application of the applicant

The applicant was an integral part of a fraudulent scheme involving the laundering of cybercrime proceeds through mule accounts

Source reference: para 10

The Court directed the trial court to proceed and conclude the trial expeditiously

Source reference: para 12
Chhattisgarh High Court

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AJAY KUMARvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · April 09, 2026

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