The account must be unfrozen, with only the disputed amount retained in fixed deposit.

The petitioner sought a direction to remove the hold or lien on her bank account. Her counsel relied on *Malcolm Murayis & Ors. v. State Bank of India and Others*, W.P. No. 1100 of 2024, and on the Standard Operating Procedure dated 10 April 2026 and guidelines discussed in *Archana v. State of Madhya Pradesh and Others*.

The Court identified Rs. 45,294.81 as the disputed amount in the present case.

1. Whether the petitioner’s account should be unfrozen while the disputed amount is separately secured, consistently with the principles in *Malcolm Murayis* and *Archana*.

2. Whether the disputed amount should remain secured pending action by the competent Judicial Magistrate under the applicable law.

The Court applied *Malcolm Murayis*, which directed that a disputed amount be placed in a fixed deposit and permitted its liquidation only after an order of the competent Judicial Magistrate within three months; absent such an order, the amount could be released to the account holder under intimation to the police agency.

It also applied *Archana*, which discusses the Ministry of Home Affairs SOP dated 10 April 2026 and the principles that account restraints should be proportionate, ordinarily limited to the suspected amount where that is sufficient, and processed through the prescribed grievance mechanism.

The Court referred to the applicable provisions of the BNSS or other law relied upon by the police agency, without specifying a particular section.

The Court considered the principles in *Malcolm Murayis* and *Archana* applicable *mutatis mutandis* to the petitioner’s case.

It ordered the specific disputed sum of Rs. 45,294.81 to be placed in a fixed deposit, while permitting the petitioner to operate the account. This preserved the disputed funds without continuing the restraint over the account as a whole.

The fixed deposit could be liquidated only upon an order of the competent Judicial Magistrate within three months; failing such an order, the petitioner could withdraw the amount under intimation to the police agency. Any further complaint concerning another transaction remained subject to action in accordance with law and the SOP.