Madhya Pradesh High CourtCriminal Procedure and EvidenceCriminal Law

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

Praveen Jaiswalv.The State Of Madhya Pradesh

MP HC Denies Second Bail To Man Accused In ₹2-Crore Jan Dhan Account Fraud, Citing No Substantial Change Since Earlier Rejection. Praveen Jaiswal 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 held that no sufficient ground for regular bail had been made out and that no substantial change in circumstances warranted reconsideration of the earlier rejection.

It also directed

The second bail application was dismissed.

01Facts

The applicant sought regular bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in a case alleging fraudulent transactions of approximately ₹2 crore from the complainant’s Jan Dhan account.

¶ 1

The prosecution alleged that the account’s registered mobile number was changed and that withdrawals and digital transactions followed.

¶ 1

The applicant was charged 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, 2000.

¶ 1

He had been in custody since 15 December 2025.

¶ 1

His earlier bail application was dismissed on merits on 1 June 2026.

¶ 1

In support of the present application, he relied, among other things, on completion of the investigation, the filing of the charge-sheet, and the claimed hostility of material witnesses.

¶ 1

The State opposed bail and submitted that no sufficient change in circumstances had been shown.

¶ 1–4

02Issues

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

¶ 1, 5

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

¶ 1, 4–5

03Law Applied

The application was considered under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which provides the relevant basis for the High Court’s consideration of regular bail.

¶ 1

The Court also applied the principle that a subsequent bail application following an earlier rejection requires consideration of whether a substantial change in circumstances has been demonstrated; it found that none had been shown.

¶ 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 case diary and the material on record, including the nature and gravity of the alleged financial offences.

¶ 3–5

Although the applicant relied on completion of the investigation and other grounds, the Court concluded that those submissions did not establish sufficient grounds for bail or a substantial change in circumstances after the earlier merits-based rejection.

¶ 3–5

It therefore declined to exercise its discretion in the applicant’s favour at that stage.

¶ 3–5

05Holding

The Court held that no sufficient ground for regular bail had been made out and that no substantial change in circumstances warranted reconsideration of the earlier rejection.

¶ 5

The second bail application was dismissed.

¶ 5
Madhya Pradesh High Court

Original Court PDF

Praveen JaiswalvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · October 23, 2026

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