Madhya Pradesh High CourtCriminal LawCriminal Procedure and Evidence

MP HC Denies Second Bail To Accused In ₹2-Crore Jan Dhan Account Case, Citing No Substantial Change Since Earlier Rejection

Rajenderv.The State Of Madhya Pradesh

MP HC Denies Second Bail To Accused In ₹2-Crore Jan Dhan Account Case, Citing No Substantial Change Since Earlier Rejection. Rajender vs The State Of Madhya Pradesh. Madhya Pradesh High Court. LawLens
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In brief

The question

Whether the applicant had established sufficient grounds for grant of regular bail under Section 483 of the BNSS.

The court held

The Court answered both issues against the applicant.

It also directed

Finding no sufficient ground for bail and no substantial change in circumstances after the prior rejection, it dismissed the second regular-bail application.

01Facts

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in a case registered for alleged offences under Sections 318, 3(5), 338, 336(3) and 340(2) of the Bharatiya Nyaya Sanhita, 2023, and Sections 66C and 66D of the Information Technology Act.

pp. 1–2

The prosecution case arose from alleged unauthorised transactions of approximately ₹2 crore through the complainant’s bank account, following a change to the mobile number linked to the account and subsequent ATM, mobile-banking and UPI transactions.

pp. 1–2

The applicant had been in custody since 11 December 2025; his earlier bail application was dismissed on merits on 1 June 2026.

p. 1

On the second application, he relied on completion of the investigation, filing of the charge-sheet, a co-accused’s release on bail, and an asserted settlement.

pp. 3–4

The State opposed bail, including on the ground that no sufficient change in circumstances had been shown.

pp. 3–4

02Issues

i.Whether the applicant had established sufficient grounds for grant of regular bail under Section 483 of the BNSS.

p. 1 · p. 5

ii.Whether any substantial change in circumstances after dismissal of the applicant’s earlier bail application warranted reconsideration.

pp. 4–5

03Law Applied

Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, provides the High Court with jurisdiction to consider an application for regular bail.

p. 1

In considering the second application, the Court assessed whether sufficient grounds and a substantial change in circumstances had been demonstrated since the earlier rejection, taking account of the nature and gravity of the allegations and the material on record.

p. 5

Provisions in the judgment · 6 · Linked ones open on LawLens

Bharatiya Nagarik Suraksha Sanhita, 2023 Section 483

Bharatiya Nyaya Sanhita, 2023 Section 318Section 3Section 338Section 336Section 340

04Reasoning

The Court considered the parties’ submissions and perused the case diary and material on record.

p. 5

It concluded that the applicant had shown neither sufficient grounds for bail nor a substantial change in circumstances since his earlier application was rejected.

p. 5

Given the nature and gravity of the allegations and the material then available, the Court declined to exercise its discretion in the applicant’s favour.

p. 5

05Holding

The Court answered both issues against the applicant.

p. 5

Finding no sufficient ground for bail and no substantial change in circumstances after the prior rejection, it dismissed the second regular-bail application.

p. 5
Madhya Pradesh High Court

Original Court PDF

RajendervsThe State Of Madhya Pradesh

Madhya Pradesh High Court · October 23, 2026

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