Introduction

Continuing its consistent judicial stance against arbitrary freezing of bank accounts in cybercrime investigations, the Rajasthan High Court, Jaipur Bench, has once again held that banks cannot impose a complete freeze on an account when only a limited disputed amount is under investigation.

The ruling was delivered in Rahul Meena v. State of Rajasthan & State Bank of India, decided on 28 January 2026, reaffirming constitutional protections for individuals facing financial hardship due to blanket account freezes.

Case Background

The petitioner, Rahul Meena, aged about 26 years and a resident of Bharatpur district, Rajasthan, approached the High Court challenging the complete freezing of his bank account maintained with State Bank of India (SBI), Kaman Branch, Bharatpur.

The bank account was frozen pursuant to a notice issued by the Inspector of Police, North CEN Crime Police Station, Bengaluru City, Karnataka, in connection with an alleged cybercrime transaction. While the entire account was rendered inoperative, the amount allegedly involved in the investigation was only around ₹4,000.

Aggrieved by the blanket freezing and the resulting disruption of his financial activities, 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.

Issues Before the Court

• Whether freezing the entire SBI bank account of the petitioner was justified when only a small disputed amount was involved.
• Whether such blanket freezing violates constitutional rights and principles of proportionality.
• What is the permissible scope of bank account freezing during cybercrime investigations.

Petitioner’s Submissions

The petitioner submitted 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 contended that:

• The account was frozen in compliance with the police notice issued from Bengaluru, Karnataka.
• As per information available, the disputed amount was approximately ₹4,000.
• 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 parties, 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 causes serious prejudice to the rights and livelihood of an individual.
• The bank can legally retain a lien only to the extent of the disputed amount, and not beyond it.
• Blanket freezing of accounts amounts to an arbitrary and disproportionate exercise of power.

The Court reiterated that preventive measures during investigation must not operate as punishment.

Final Order and Directions

The writ petition was disposed of with the following directions:

• The respondent bank was directed to defreeze the petitioner’s SBI bank account.
• The petitioner was permitted to operate and transact through the account normally.
• Only the disputed amount of ₹4,000 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.