Defreezing of frozen bank account may be ordered when investigation has progressed and continued freeze serves no useful purpose.

A bank account frozen during a criminal investigation may be ordered defreezed where the investigation has substantially progressed, cooperation has been secured, and the record does not clearly justify continued freezing. The Court noted that the freeze was hindering business operations and served no useful purpose once a charge sheet had been filed. Relief was granted with protective conditions, including furnishing a bank guarantee for the specified amount and an undertaking to cooperate with any further investigation and the trial court.

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Issues: Whether the petitioner was entitled to defreezing of its bank account frozen during investigation, and whether such relief could be granted subject to conditions.

Analysis: The account had been frozen in connection with an ongoing criminal investigation, but the petitioner later cooperated with the Investigating Officer pursuant to the Court's directions, and the investigation was stated to have been completed with a charge sheet filed. The record did not contain any clear proof of the exact amount traced to the petitioner's account, while the account freeze continued to impede the petitioner's business operations. In these circumstances, continued freezing was found to serve no useful purpose, though the Court considered it appropriate to safeguard the investigation and possible trial by imposing conditions.

Conclusion: The petitioner was entitled to defreezing of the bank account, subject to furnishing a bank guarantee for the specified amount and giving an undertaking to cooperate with any further investigation and with the trial court.

Ratio Decidendi: Where the investigation has substantially progressed and the record does not justify continued freezing, the court may order defreezing of a bank account subject to conditions that protect the investigation and trial.

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