Only disputed cyber-fraud amounts may remain secured; the bank account must otherwise be unfrozen.

The petitioner invoked Article 226 of the Constitution seeking removal of a hold or freeze on his AU Small Finance Bank account and seeking that only the disputed amounts of ₹2,275 and ₹9,500 be restrained.

He relied on *Malcolm Murayis & Ors. v. State Bank of India and Others* and submitted that the principles in that decision covered his case.

The Court also considered the later decision in *Archana v. State of Madhya Pradesh and Others*, which discussed the Ministry of Home Affairs’ Standard Operating Procedure (SOP) for grievances concerning accounts put on hold through the NCRP-CFCFRMS.

1. Whether the petitioner’s account should remain frozen in full when the identified disputed amounts were ₹2,275 and ₹9,500.

2. Whether those disputed amounts should instead be secured while permitting the petitioner to operate the account, subject to directions under the applicable law and the SOP.

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

In *Malcolm Murayis*, the Court directed that disputed cyber-fraud amounts be placed in fixed deposits and permitted their liquidation if the investigating agency did not obtain orders from the competent Magistrate within three months.

In *Archana*, the Court discussed the SOP dated 10 April 2026 and guidelines requiring account restraints to be proportionate, ordinarily limited to the suspected amount where that would sufficiently protect the investigation, and processed through the prescribed grievance mechanism.

The present order refers to action under the relevant provisions of the BNSS or other law relied upon by the police agency.

The Court held that *Malcolm Murayis* and *Archana* applied *mutatis mutandis*.

Applying their approach, it distinguished the specific disputed sums from the account as a whole: the sums of ₹2,275 and ₹9,500 were to be secured in fixed deposits, while the account itself was to be unfrozen so the petitioner could operate it.

The Court also preserved the bank’s ability to act in accordance with law and the SOP if it received a complaint concerning another transaction.

The disputed amounts may be liquidated only after orders are passed by the competent Judicial Magistrate within three months; failing that, the petitioner may withdraw them under intimation to the police agency.

The bank may take appropriate action under law and the SOP if another complaint is received.