Seized electronic devices must be released once evidentiary data is extracted and preserved to prevent undue hardship.

The Petitioners, lab contractors and businessmen, were implicated in a corruption case involving the Food Corporation of India (FCI)

During search operations between 05.03.2025 and 07.03.2025, the CBI seized 19 documents, six mobile phones, a laptop, and locker keys from them

The Trial Court (Special Judge, CBI) ordered the release of these articles on 09.01.2026 and accepted indemnity bonds on 11.02.2026

Despite these orders, the CBI failed to return the items, orally advising the Petitioners to travel from Bargarh to New Delhi to collect them

The Petitioners approached the High Court seeking enforcement of the release orders, citing financial hardship and the risk of damage to the electronic devices

The CBI opposed the release, arguing that the investigation was at a nascent stage and that the devices contained vital evidence linked to illegal money parking

1. Whether the Investigating Agency can justify the continued retention of seized electronic devices after a competent Trial Court has directed their release and the necessary data has presumably been preserved

2. Whether the insistence by the CBI for the Petitioners to travel to New Delhi for the release of property seized within the jurisdiction of the local Trial Court is arbitrary and oppressive

The court primarily applied Section 482 of the Code of Criminal Procedure (mirrored by Section 528 of the Bharatiya Nagarik Suraksha Sanhita) regarding the inherent powers of the High Court to prevent abuse of the process of law

The principle established in CBI v. Saroj Kumar Das (2026), which dictates that seized property should not be retained longer than absolutely necessary and should be released upon securing evidentiary value (e.g., hash values/data extraction) to avoid undue hardship

The Court further referenced the CBI Manual and the Information Technology Act, emphasizing the use of "hash values" to maintain the integrity of digital evidence while allowing the return of physical hardware

The Court balanced the State's investigative powers against the individual’s right to property and livelihood

It observed that the CBI had already had ample time to extract and preserve digital data, thereby securing the evidentiary value of the devices through hash values

The Court reasoned that since the substantial part of the investigation regarding the data was completed, the hardware served no further immediate purpose for the prosecution

It criticized the CBI's failure to comply with the Trial Court's orders as arbitrary and noted that forcing senior citizens to travel to New Delhi for property release was an unreasonable burden

The Court concluded that continued retention would cause "irreparable prejudice" and "permanent damage" to the electronics without advancing the cause of justice

The Court held that the prolonged retention of the articles was arbitrary and lacked compelling justification

The Court directed the immediate release of the seized mobile phones, laptops, and locker keys to the Petitioners

This release is subject to stringent conditions to ensure the items are produced if required during the trial, and all prior interim orders were vacated