Anticipatory Bail Refused in Rs 537-Cr Mule-Account Case

Anticipatory Bail Only in Exceptional Circumstances: Rajasthan High Court Refuses Protection in Alleged Rs 537-Crore Mule-Account Fraud

Published: 29 October 2026 · NyayVidhan

The Rajasthan High Court at Jodhpur refused anticipatory bail to Praveen Arora, accused in a CBI case alleging that four ‘mule’ current accounts, opened on false KYC documents for non-existent firms, handled about Rs 537 crore (paras 5, 10). The Court noted that his earlier petition in this FIR had been dismissed as not pressed, a fact not disclosed when he obtained protection in another FIR, and that he had not appeared despite a notice (para 6).

Key holdings

Anticipatory bail needs exceptional circumstances, following P. Chidambaram v. Directorate of Enforcement (para 8).

The Court recorded that the dismissal of the petitioner's earlier petition on the same FIR as not pressed was not disclosed when he obtained protection in another FIR (para 6).

Non-appearance before the investigating officer despite a served notice was also recorded (para 6).

On the material collected so far, nothing suggested false implication (para 7).

The refusal carries no comment on the merits of the case (para 9).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

The CBI/ACB, Jodhpur, registered an FIR against ten persons, including the petitioner, under Section 61(2) read with Sections 318, 336 and 340 of the BNS and Section 13(2) read with Section 13(1)(a) of the Prevention of Corruption Act (opening paragraph, para 5). The prosecution alleges that in June-July 2024 four mule current accounts were opened at a Sri Ganganagar bank branch for non-existent firms, allegedly with bank officials' connivance, and used for cyber-fraud money (para 5). After the trial court refused relief, he applied under Section 482 BNSS, saying a search found nothing incriminating and he would cooperate (paras 3, 6). The Special Public Prosecutor said he arranged premises and GST registrations and was not appearing despite notice (para 4).

Court's Findings

The Court set out the prosecution case: a source report, a preliminary inquiry and an FIR alleging that about Rs 537 crore passed through the four accounts (para 5). Drawing on the trial court's order, it noted that a co-ordinate Bench had stayed the petitioner's arrest on 16.07.2026 in his challenge to another FIR, but that he had not disclosed that his earlier High Court petition in the present FIR had been dismissed as not pressed (para 6). It also recorded that, despite a notice served on 06.08.2026, he had neither appeared before the investigating officer nor cooperated (para 6). On the evidence collected so far, he allegedly provided the premises for the four firms and arranged their GST registrations through a chartered accountant, himself an accused; one statement says he sought identity documents for opening firms against Rs 20,000 per account, and a witness called a rent agreement fabricated (para 7). The record did not suggest false implication (para 7). Following P. Chidambaram v. Directorate of Enforcement, it held that anticipatory bail, an extraordinary remedy, needs exceptional circumstances, and found none (para 8). It refused relief without commenting on the merits (para 9).

Legal Principle

Anticipatory bail is an extraordinary remedy, granted only where the court is satisfied that exceptional circumstances exist, such as where it clearly appears that no prima facie case is made out and the applicant faces false arrest. Where the material collected so far does not suggest false implication, protection will be refused (paras 7-9).

NyayVidhan's view · Practice note

Why It Matters

For anyone seeking anticipatory bail, this order shows that conduct before the court and the investigating agency can matter as much as the allegations. The Court recorded two points of conduct: an earlier High Court petition on the same FIR, dismissed as not pressed, was not disclosed when protection was obtained in another FIR, and a notice from the investigating officer went unanswered (para 6). Applicants should disclose every earlier petition and its outcome, and answer notices before seeking protection. In Senior Intelligence Officer v. Mohammed Kamran, the Supreme Court held that pursuing relief without disclosing adverse orders lacks the good faith bail requires. The refusal here carries no comment on the merits (para 9).

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.

Precedents Relied Upon

P. Chidambaram v. Directorate of Enforcement AIR 2019 SC 4198
Relied Upon Discussed at ¶ 8
Cited for its interpretation of Section 438 CrPC: anticipatory bail should be granted only when the court is satisfied that exceptional circumstances exist for resorting to that extraordinary remedy. The High Court found no such circumstances in this case (para 8).