Introduction

Reiterating its firm stand against arbitrary and blanket freezing of bank accounts, the Rajasthan High Court, Jaipur Bench, has once again ruled that banks cannot freeze an entire account when only a specific disputed amount is under investigation.

The ruling was delivered in Sachin v. State of Rajasthan & Indian Bank, decided on 28 January 2026, further strengthening constitutional safeguards for individuals affected by cybercrime investigations.

Case Background

The petitioner, Sachin, aged about 20 years and a resident of Mundawar, Alwar district, Rajasthan, approached the High Court challenging the complete freezing of his bank account maintained with Indian Bank, Mansarovar Branch, Jaipur.

The bank account was frozen pursuant to a notice issued by the Inspector of Police, Cyber Crime Police Station, Asansol–Durgapur Police Commissionerate, West Bengal, in connection with an alleged cybercrime transaction. Despite the freeze on the entire account, the amount allegedly involved in the investigation was only around ₹12,100.

Aggrieved by the blanket freezing and the resulting severe financial hardship, the petitioner invoked the writ jurisdiction of the High Court under Article 226 of the Constitution of India, alleging violation of his fundamental rights under Articles 14, 19(1)(g), and 21, and breach of principles of natural justice.

Issues Before the Court

• Whether freezing the entire Indian Bank account of the petitioner was legally sustainable when only a limited disputed amount was involved.
• Whether such blanket freezing amounts to an arbitrary and unconstitutional restriction on the petitioner’s rights.
• What is the permissible scope of bank account freezing during cybercrime investigations.

Petitioner’s Submissions

The petitioner contended that:

• He had never misused his bank account for illegal or fraudulent transactions.
• He was not involved in any cybercrime.
• The freezing of the entire account was arbitrary, excessive, and unconstitutional.
• He was ready and willing to cooperate with the investigating agencies and bank authorities whenever required.
• At most, only the disputed amount could be frozen, and the remaining balance should be released for lawful use.

Respondents’ Submissions

The respondent bank submitted that:

• The account was frozen strictly in compliance with the police notice issued from West Bengal.
• As per information available, the disputed amount was approximately ₹12,100.
• The petitioner should be directed not to close or discontinue the bank account until the investigation or criminal proceedings were concluded.

The petitioner’s counsel agreed to these limited safeguards.

Observations of the High Court

After hearing both sides, the High Court observed that:

• There was no prima facie material to establish the petitioner’s involvement in any fraudulent or illegal activity.
• Freezing an entire bank account results in serious prejudice to the rights and livelihood of an individual.
• The bank is legally entitled to retain a lien only to the extent of the disputed amount related to the alleged offense.
• Blanket freezing of accounts is disproportionate, arbitrary, and unsustainable in law.

The Court reiterated that investigative measures must remain preventive and cannot assume a punitive character.

Final Order and Directions

The writ petition was disposed of with the following directions:

• The respondent bank was directed to defreeze the petitioner’s Indian Bank account.
• The petitioner was permitted to operate and transact through the account normally.
• Only the disputed amount of ₹12,100 shall remain frozen.
• The petitioner shall cooperate with the bank authorities and investigating agencies and appear whenever required.
• The petitioner shall not close or discontinue the bank account without prior permission.
• If, after investigation, the petitioner is found involved in any illegal transaction, he shall be liable to face action in accordance with law.
• All pending applications, if any, stood disposed of.