Bank accounts can be treated as property and frozen under criminal procedure when directly linked to an alleged offence.

Section 102 of the Code of Criminal Procedure uses the broad expression "any property", and that term includes a bank account when it has a direct nexus with the alleged offence. A police officer investigating such an offence may seize the account or issue a prohibitory order restraining its operation to preserve assets traceable to the suspected wrongdoing. The construction was supported by the need for effective investigation, including in corruption matters, so that ill-gotten assets are not withdrawn before trial. A bank account is therefore capable of seizure or freezing under Section 102 where the required connection with the offence exists.

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Issues: Whether a bank account can be treated as property for the purpose of seizure under Section 102 of the Code of Criminal Procedure, and whether a police officer investigating an offence can issue a prohibitory order restraining operation of such account when the account has a direct link with the alleged offence.

Analysis: Section 102 uses broad expressions, namely "any property" and "any offence", and its object is to enable seizure of property found under suspicious circumstances connected with commission of an offence. The Court noted the divergent views of the High Courts, but held that a narrow construction would defeat effective investigation, especially in corruption cases where assets representing ill-gotten wealth may otherwise be withdrawn before trial concludes. The scheme of the Prevention of Corruption Act, 1988, particularly the provisions concerning punishment, fine, inspection of bankers' books, and application of the Code of Criminal Procedure, supported a construction that preserves assets having a direct nexus with the alleged offence. On that basis, bank accounts were treated as property capable of being seized or frozen under Section 102 when the requisite connection with the offence exists.

Conclusion: A bank account is property within Section 102 of the Code of Criminal Procedure, and a police officer may seize or prohibit operation of the account if it has direct links with the offence under investigation.

Final Conclusion: The legal position was settled in favour of police power to freeze or seize linked bank accounts during investigation, though no interference was made with the specific order under challenge because it had already been acted upon.

Ratio Decidendi: For the purpose of investigation, the expression "property" in Section 102 of the Code of Criminal Procedure includes a bank account when the account is connected with the alleged offence, and such account may be seized or frozen to preserve assets traceable to that offence.

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