The Delhi High Court has appreciated a Delhi Police Investigating Officer (IO) for conducting an elaborate “scientific investigation” using information technology tools to trace alleged fraudsters involved in creating fake GST registrations by misusing PAN cards and other credentials of innocent persons.

Justice Girish Kathpalia made the observations while refusing to grant anticipatory bail to one Raj Kumar, accused of generating fake GST numbers using credentials of unsuspecting persons and supplying fake GST details to a co-accused for generating fake invoices and e-way bills.

The Court appreciated the detailed status report filed by the IO, noting that it described the technical investigation undertaken to “zero down on the alleged fraudsters.”

“It is indeed laudable that the Investigating Officer has filed an elaborate status report dated 25.05.2026 describing the technical investigation with the use of information technology tools in order to zero down on the alleged fraudsters. Such scientific investigation deserves to be appreciated,” the Court observed.

The FIR was registered at Police Station Cyber, Outer North, for offences under Sections 420, 419, 468, 471 and 120B of Indian Penal Code, 1860.

The prosecution alleged that the complainant discovered, after receiving an Income Tax Department notice, that two GST firms had been linked to her PAN card despite her never having applied for GST registration or having any knowledge of the businesses.

She alleged that her PAN and other credentials had been misused to obtain GST registrations and conduct illicit financial activities in her name.

During investigation, the IO visited the locations from where the firms were allegedly operating but found that no such firms were existing.

The investigation then proceeded through technical means, with the IO tracing the mobile number used for obtaining OTPs for filing GST returns, identifying linked email IDs and examining the bank account connected with one of the GST numbers.

The investigation connected one of the email IDs with a mobile number registered in Kumar's name. His email ID was also found linked with another email account as a recovery email ID.

The prosecution alleged that Kumar was involved in generating GST numbers of fake entities and providing those numbers, along with associated mobile numbers and email IDs, to co-accused Aman Bisht.

It was alleged that the fake GST numbers were thereafter used to generate invoices and e-way bills, while clients allegedly made payments directly to Kumar.

Kumar's counsel argued that the case rested primarily on the disclosure statement of a co-accused and that the incriminating mobile phones did not belong to him. It was also claimed that Kumar was innocent and was not a beneficiary of the alleged fraud.

The State, on the other hand, argued that there was strong technical evidence apart from the disclosure statements, including mobile numbers and email IDs allegedly used in filing fake GST returns and receiving OTPs being registered in Kumar's name.

It was also submitted that the accused had been evading the investigation and that proceedings to declare him a proclaimed offender were nearing culmination.

Dismissing the plea, the Court noted that the probe concerning Kumar was still underway to ascertain the extent of the alleged fraud.

“Filing of fake GST returns, that too by misusing the PAN Cards and other credentials of innocent public persons has extremely serious consequences not just on the persons whose particulars have been hacked by the accused persons from different fora, but also has tremendous ramifications on economy of the country,” the Court said.

Considering the pending technical investigation, Kumar's alleged non-cooperation and the requirement of custodial interrogation expressed by the IO, the Court held that it was not a fit case for anticipatory bail.

The Court also noted that Kumar was allegedly involved in three other FIRs concerning financial fraud, including one case under the Prevention of Money Laundering Act.

“Grant of anticipatory bail in such cases would not just be contrary to the judicially sanctified parameters, but also send wrong signals to the society at large. Therefore, I do not find it a fit case to grant anticipatory bail. The anticipatory bail application is dismissed,” the Court said.

Title: RAJ KUMAR v. THE STATE (NCT OF DELHI)

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