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Submissions on behalf of the Respondent

17. Ms. Meenakshi Dahiya, learned APP for the State opposes the bail applications. It is submitted that FIR No. 50/2024 arises out of a larger cyber-fraud scam run through the trading application ―CHC- SES‖, where multiple victims, including Vishal Sodhi, Rajbir Yadav, Shailender Kumar and Manoj Kumar were induced to transfer monies into 24 different bank accounts. The preliminary enquiry pegs the collective loss at approximately ₹2.38 crore across these complaints.

24. Learned APP also places on record criminal antecedents/other involvements of both petitioners, by reference to communications received from various police units across States concerning multiple FIRs involving ―R.S. Trading‖.

25. On the strength of the foregoing, the learned APP for the State earnestly opposes the grant of bail and submits that the material collected during investigation unmistakably establishes the complicity of both petitioners in a well-organised cyber-fraud syndicate. The modus operandi involved the creation of forged identities and the opening of multiple bank accounts which were thereafter sold for use in cheating operations. It is emphasised that the prosecution witnesses, including bank officials and the landlord of the rented premises, have already identified the petitioners and linked them to the forged documents and premises used for the offence. The investigating agency maintains that the conspiracy is part of a larger and continuing network, several of whose members are yet to be apprehended or traced. Given the nature of the evidence, the magnitude of the fraud, and the foreign connections of the accused, there exists a substantial risk of tampering with evidence, repetition of similar offences, and abscondence if either petitioner is released on bail. The State accordingly contends that the gravity, scale and sophistication of the operation render the petitioners unfit for enlargement on bail at this stage.

35. With that brief preface, this Court may turn to the present case.

36. In the present case, FIR No. 50/2024 discloses a well co- ordinated cyber-fraud operation wherein victims were induced to transfer substantial sums of money into multiple bank accounts created and operated through forged identities. The contribution of petitioner Paramjit Kharb in the entire operation of the alleged syndicate is not a matter for minute dissection at this stage. However, from the material placed before this Court, the main issue that emerges is whether he was responsible for the preparation of forged Aadhaar and PAN cards and the subsequent opening of bank account under a false identity.

42. The contention that the petitioners are without criminal antecedents is also rebutted by the prosecution by placing on record the details of several other FIRs registered against them across multiple states, all concerning the operations of the alleged firm ―R.S. Trading‖. As far as both the petitioners - Paramjit Kharb and Ram Kumar Rama are concerned, the status report lists multiple cases against them together, including FIR No. 34/2024, Crime Branch, Mumbai; FIR No. 23/2024, Cyber Police Station (North Region), Mumbai; FIR No. 99/2024, Cyber Cell Headquarters, Shivaji Nagar, Pune; FIR No. 03/2024, Cyber Police Station, Nagaur, Rajasthan; FIR No. 12/2024, State Cyber Headquarters, Bhopal; FIR No. 19/2024, Cyber Crime Police Station, Kanchipuram; FIR No. 58/2024, CCID-I, Avadi, Chennai; FIR No. 06/2024, Cyber Crime Police Station, Sector-36, Noida; and FIR No. 26/2024, Cyber Crime (West), Sector- 22, Palam Vihar, Gurugram, Haryana.