Prima facie evidence of managing mule accounts for organized cyber fraud justifies denial of regular bail.

The Ministry of Home Affairs' "Samanvay" portal flagged 17 "mule accounts" at DCB Bank, Raipur, used to funnel cyber fraud proceeds

Investigation revealed that one such account (No. 21211100010353), registered to Jaspreet Singh, was used for illegal transactions totaling ₹26,33,550

Singh alleged in his memorandum statement that he sold the account to the applicant, Manoj Verma, for ₹5,000

The prosecution alleged that the applicant operated the account and withdrew approximately ₹26,30,485 within a short period

The applicant, arrested on December 21, 2025, moved this first bail application under Section 483 of the Bhartiya Nagrik Suraksha Sanhita (BNSS), 2023, following the registration of an FIR for organized crime and fraudulent transactions

1. Whether the applicant is entitled to regular bail under Section 483 of the BNSS given the nature of his involvement in a structured cyber fraud conspiracy

2. Whether the evidence collected, including memorandum statements and financial records, establishes a prima facie case against the applicant

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

The applicant was charged under the Bhartiya Nyay Sanhita (BNS), 2023, including Section 111 (organized crime), Section 3(5) (joint liability), and Sections 317(2), 317(4), and 317(5) (dealing with stolen property and proceeds of crime)

The principle that bail may be withheld in cases involving organized, profit-oriented criminal conspiracies where there is a high magnitude of fraud and a risk of the accused absconding or tampering with evidence

The Court analyzed the Investigating Officer’s affidavit, which detailed how the applicant allegedly managed a "mule account" to facilitate large-scale cyber fraud

Although the applicant argued that the charge-sheet had been filed and no proceeds of crime were directly recovered from him, the court found that the memorandum statement of the account holder, Jaspreet Singh, coupled with the applicant's own confession, established a direct nexus between the applicant and the illegal transactions

The court noted that the swift withdrawal of over ₹26 lakhs from the account linked the applicant to a "deep-rooted, structured, and profit-oriented criminal conspiracy"

It reasoned that the organized nature of the offense and the systematic siphoning of funds from multiple victims nationwide outweighed the applicant's plea for liberty

Furthermore, the court accepted the State's contention that the applicant posed a flight risk and could potentially influence witnesses if released

It held that a prima facie case was established regarding the applicant's integral role in the fraudulent scheme, and the gravity of the offense necessitated continued detention

The Court granted the trial court liberty to proceed with the trial expeditiously and directed the registry to communicate the order to the concerned court