1. Writ petition concerning freezing and seizure of bank accounts in cyber financial crime matters. (Para 2 , 3 )
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2026 Supreme(Online)(Raj) 20310
HIGH COURT OF RAJASTHAN
Anand Sharma, J
RIJVAN S/O ILIYAS – Appellant
Versus
RESERVE BANK OF INDIA – Respondent
CW 17166 / 2026
Advocates:
For the Appellants/Petitioners: Arafat Hussain
For the Respondents: Sunita Meena, Bhuvnesh Sharma
For the Appellants/Petitioners: Arafat Hussain
For the Respondents: Sunita Meena, Bhuvnesh Sharma
The court held that where a controversy regarding the freezing or seizure of bank accounts in cyber financial crimes is squarely covered by a prior judgment of the same court, the existing directions and observations shall apply mutatis mutandis to the current case.
Headnote:(A) Banking Law - Freezing and seizure of bank accounts in cyber financial crime - Disposal of petition based on precedente - Where a controversy is squarely covered by a prior judgment of the Court containing specific directions and observations regarding the alarming increase in cases of freezing, debit-freezing, lien marking, holding or seizure of bank accounts in cyber financial crime, the same directions and observations shall apply mutatis mutandis to subsequent petitions. (Paras 2-4)
Facts of the case:
A writ petition was filed seeking relief against the freezing or seizure of a bank account in the context of investigations into cyber financial crimes.
Findings of Court:
The Court noted that the legal controversy involved in the present petition was squarely covered by a previous judgment delivered by the same Court in a batch of related petitions addressing the issues of account freezing and lien marking in cyber crime cases.
Issues: Whether the present writ petition could be disposed of by applying the directions and observations issued in a prior judgment dealing with similar circumstances of bank account freezing in cyber financial crimes.
Ratio Decidendi: Since the issues raised in the petition were identical to those already adjudicated and resolved by the Court in a prior judgment, the observations and directions issued in that previous case are applicable to the present matter mutatis mutandis.
Result: Writ petition disposed of.
Legal Category Hierarchy
Table of Contents
2. Counsel conceded the controversy was squarely covered by a prior judgment disposing of similar writ petitions. (Para 2 )
3. Court noted an alarming increase in cases of freezing, debit-freezing, lien marking, and seizure of bank accounts in cyber financial crime. (Para 3 )
4. A prior judgment's observations and directions apply mutatis mutandis to cases involving similar issues of bank account freezing in cyber crime. (Para 2 , 3 , 4 )
5. Writ petition disposed of in light of the judgment in Shree Balaji Enterprises case, with its directions applying mutatis mutandis. (Para 4 , 5 )
6. Can a writ petition be disposed of by applying a prior judgment mutatis mutandis when counsel concede the controversy is covered?
Yes, if counsel for both parties concede the controversy is squarely covered by a prior judgment, the court may dispose of the petition by applying that judgment's observations and directions mutatis mutandis. (Para 2 , 4 )
7. What matters are covered by the directions in Shree Balaji Enterprises?
The directions cover cases concerning freezing, debit-freezing, lien marking, holding, or seizure of bank accounts in cyber financial crime and all incidental matters. (Para 3 )
Order
30/09/2026
1. Ms. Devakriti Vashishtha, Adv. & Mr. Kartikeya Shukla for Mr. Bhuvnesh Sharma, AAG appeared and accepted notices on behalf of the respondents.
2. Learned counsel for the parties at the outset fairly conceded that the controversy involved in this writ petition is squarely covered by judgment dated 20.08.2026 passed by this Court in the case of Shree Balaji Enterprises vs. Reserve Bank of India & Others (S.B. Civil Writ Petition No. 2679/2026 & others connected writ petitions) whereby all the writ petitions were disposed of by this Court with certain directions and observations.
3. This Court in the case of Shree Balaji Enterprises (supra), while taking note of alarming increase in the cases concerning freezing, debit-freezing, lien marking, holding or seizure of bank accounts in cyber financial crime and all incidental matters, disposed of batch of petitions with certain directions and observations.
4. Thus, instant writ petition is also disposed of in the light of judgment of this Court delivered in the case of Shree Balaji Enterprises (supra). The observations and directions issued by this Court in the above case shall mutatis mutandis apply to the present writ petition.
5. Pending applications, if any, stand disposed of.
