After a detailed hearing, the Punjab and Haryana High Court on December 22 refused to grant regular bail to Rajeev Kumar Rana, an accused in the large-scale Adarsh Group financial fraud being investigated by the Serious Fraud Investigation Office (SFIO). The Court held that prolonged custody alone could not justify bail when earlier rejection orders had already been upheld by the Supreme Court.
The decision was delivered by Justice Manisha Batra, who also directed the trial court to speed up the long-pending proceedings.
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Background of the Case
The case traces its roots to a 2018 order of the Ministry of Corporate Affairs directing the SFIO to probe the affairs of the Adarsh Group of Companies and over 125 associated LLPs. The investigation followed allegations that thousands of crores belonging to depositors of Adarsh Credit Cooperative Society Limited were siphoned off through shell entities and questionable financial statements.
Rajeev Kumar Rana was named as accused number 177 in the complaint. According to SFIO, he was a partner holding an 18 percent stake in a real estate project linked to the group and allegedly misused his position as an authorised signatory to divert funds running into several tens of crores.
He was arrested in July 2022 and has remained in custody since then.
Arguments by the Petitioner
Senior counsel appearing for Rana told the Court that the accused had spent more than three years in jail without the trial even beginning. It was argued that despite the filing of the complaint in 2019, charges had not been framed due to the large number of accused and entities involved.
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The defence also pointed out that Rana had earlier cooperated with the investigation and had been granted bail in connected cases in Rajasthan. Stressing the constitutional right to personal liberty, counsel submitted that “continued incarceration without progress in trial amounts to punishment before conviction.”
Medical grounds and alleged repayment of funds were also cited in support of the bail plea.
Stand of the SFIO
Opposing the petition, SFIO’s counsel argued that this was a second successive bail application, filed after the High Court had already rejected the first plea in 2023 - a decision later affirmed by the Supreme Court.
The prosecution told the Court that no substantial change in circumstances had occurred since the earlier rejection. It was also argued that economic offences involving public money stood on a different footing and required stricter scrutiny.
“The allegations involve deep-rooted conspiracy and massive financial loss to innocent investors,” the SFIO submitted, warning that granting bail could risk absconding.
Court’s Observations
Justice Manisha Batra examined the scope of bail under Section 212(6) of the Companies Act, which imposes strict twin conditions for offences involving corporate fraud. Referring to Supreme Court precedents, the Court noted that such conditions could be relaxed only in exceptional cases where delay seriously infringes fundamental rights.
However, the Court found that Rana had failed to demonstrate any meaningful change in circumstances since his earlier bail rejection.
The bench observed, “Merely on the ground of prolonged incarceration, the petitioner cannot be held entitled to seek the benefit of bail, particularly when the previous rejection has been upheld by the Supreme Court.”
The Court also took note of the gravity of allegations, including claims of misappropriation exceeding ₹80 crore.
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The Decision
Concluding that no fresh ground justified reconsideration, the High Court dismissed the second bail petition. At the same time, the Court directed the trial court to expedite proceedings and explore measures such as separating trials of absconding accused to avoid further delay.
The Court clarified that its observations would not influence the merits of the case during trial.
Case Title: Rajeev Kumar Rana v. Serious Fraud Investigation Office
Case No.: CRM-M-23555-2025
Case Type: Regular Bail Petition
Decision Date: 22 December 2025
