Police power to freeze bank accounts is limited; summons under Section 94 do not authorise debit freezes without magistrate-ordered seizure or attachment.

Territorial nexus is satisfied where part of the cause of action-here debit freezing-occurs within the court's limits, rendering the writ maintainable; the substantive issue is whether a Section 94 BNSS notice permits police to direct debit freezes. Section 94 merely summons production and does not authorise debit freezing; continued restraint of bank accounts requires seizure/attachment compliance and magistrate orders under the Sanhita's seizure/attachment regime. The impugned debit-freeze is quashed and the bank must restore operation of the account unless and until lawful magistrate-sanctioned steps under the seizure/attachment procedures are taken.

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Issues: (i) Whether this High Court has territorial jurisdiction under Article 226(2) to entertain a writ petition challenging debit freezing of a bank account maintained within its territorial limits; (ii) Whether a notice under Section 94 of the Bhartiya Nagrik Suraksha Sanhita, 2023 authorises a police officer to direct a bank to debit freeze a bank account without appropriate magistrate orders under Sections 106/107 of the Sanhita.

Issue (i): Whether this High Court has territorial jurisdiction to entertain the writ petition.

Analysis: The pleadings assert that the debit freezing directed by notice affected the petitioner's bank account at the Kankurgachi branch within the territorial limits of this Court and that the grievance is confined to the freezing of that account. Jurisdictional tests require that material facts constituting part of the cause of action arise within the territorial jurisdiction for clause (2) of Article 226 to be attracted; the nature and substance of the cause of action are material in this inquiry.

Conclusion: The territorial nexus for part of the cause of action is established by the debit freezing of the account within this Court's jurisdiction; the writ petition is maintainable before this High Court.

Issue (ii): Whether the police notice under Section 94 BNSS, 2023 authorised the debit freezing of the petitioner's bank account without magistrate orders under Sections 106/107.

Analysis: Section 94 BNSS relates to summons to produce documents or things and does not itself empower police to effect debit freezing of bank accounts. Sections 106 and 107 distinguish seizure (immediate securing of property during investigation) from attachment (which requires application to and orders by the magistrate, including show-cause and opportunity). The impugned notice effected a debit freeze without record of any magistrate order or an application under Section 107 and without reporting seizure/attachment to the jurisdictional magistrate as required for continuing restraints on bank accounts.

Conclusion: The direction in the notice to debit freeze the petitioner's bank account was not authorised by Section 94 and cannot be continued indefinitely in the absence of appropriate magistrate orders under Sections 106/107; the debit freeze is quashed and the bank is directed to allow operation of the account.

Final Conclusion: The writ petition is maintainable in this High Court and, on the merits, the part of the police notice mandating debit freeze of the petitioner's account is set aside; the petitioner's account shall be permitted to operate, subject to any future lawful steps taken in accordance with Sections 106/107 of the Bhartiya Nagrik Suraksha Sanhita, 2023.

Ratio Decidendi: A notice under Section 94 of the Bhartiya Nagrik Suraksha Sanhita, 2023 does not empower police to order debit freezing of bank accounts; attachment or continued restraint of bank accounts requires compliance with seizure/attachment procedures and appropriate magistrate orders under Sections 106 and 107 of the Bhartiya Nagrik Suraksha Sanhita, 2023.

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