Anticipatory Bail Application Of Nitin Naresh In Extortion Case Rejected By Jaipur District Court

A Jaipur court has rejected the anticipatory bail application filed by Nitin Naresh in an alleged extortion case registered at Shastri Nagar Police Station, Jaipur, holding that the circumstances of the case, the material collected during the investigation and the need for further investigation did not justify granting pre-arrest protection.

The order was passed on October 28, 2026, by the Court of Additional Sessions Judge No. 7, Jaipur Metropolitan-II, presided over by Judge Renuka Singh Hudda, RJS. The application, registered as Anticipatory Bail Application No. 358/2026, arose from FIR No. 267/2026, registered under Sections 308(2), 308(3), 351(2) and 61(2) of the Bharatiya Nyaya Sanhita, 2023. The order also refers to Section 3(5) of the BNS while discussing the allegations and the investigation.

The court dismissed the application under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, which provides for anticipatory bail.

The case centres on allegations that money was demanded in connection with threats of further adverse publications concerning a complainant and an investment organisation with which he claimed to be associated. The court examined the complaint, the alleged emails, documents relating to a payment of ₹11,700, the arguments advanced by both sides and the status of the police investigation before reaching its decision.

The Allegations: Emails, Demands for Money and Threats of Further Publications

According to the facts recorded in the judicial order, the complaint was filed by Aniruddh Saran Purohit, who stated that he represented an investment organisation identified in the order as Tera Invest, associated with Terra Vision Investment LLC, in India.

The complainant claimed that he was responsible for operating the organisation’s official email account and had access to communications received through it. He alleged that adverse articles concerning the organisation and himself had been published over several months by Inventiva and individuals associated with the publication, with Nitin Naresh identified as a principal accused.

The complaint further alleged that emails were sent demanding payments and warning that additional adverse articles or online publications would follow if the demands were not met.

The order identifies August 26, 2026, as the date of the first alleged threatening email. It records that another email was received on September 3, 2026, allegedly reiterating the demand for money and threatening further adverse publications if payment was not made.

The complainant alleged that the communications caused continued pressure and harassment and that he made a payment in the expectation that the demands and threats would stop.

These assertions formed the foundation of the extortion allegations considered by the court. They remain allegations in a criminal case and must be distinguished from a final determination of criminal liability.

The ₹11,700 Payment: A Key Element in the Court’s Assessment

One of the significant aspects of the order is the alleged payment of ₹11,700 on September 3, 2026.

According to the complaint as summarised by the court, the complainant deposited the money through a cash-deposit machine at an HDFC Bank branch in Shastri Nagar, Jaipur. The order records the transaction number as 1636 and identifies the receiving account as one held in the name of Nine Network Private Limited, the entity described in the judgment as the owner of Inventiva.

The complainant alleged that the deposit was made because of the pressure generated by the preceding emails and the threat of further adverse publications. He also claimed that another email demanding additional money arrived on the same day, shortly after the payment had been made.

The complainant relied on the email communications and the bank deposit documentation to support his allegations. The prosecution and complainant’s counsel placed these materials before the court during the anticipatory bail proceedings.

The payment was an important consideration in the court’s assessment because the alleged demand for money was directly connected, according to the complaint, with the threatened continuation or cessation of adverse publications.

However, the existence of a bank transaction does not by itself conclusively establish the identity of the person who made a demand, the intention behind a payment or the commission of extortion. Those questions remain matters for investigation and adjudication on the evidence.

Defence Denies the Allegations and Questions the Link to the Emails

During the hearing, the defence sought to persuade the court that Nitin Naresh was innocent and had been implicated in the case without sufficient justification.

According to the submissions recorded in the order, the defence denied that Naresh had sent the alleged emails, demanded money from the complainant or issued threats. It argued that the material before the court did not establish that the email address from which the alleged demands were sent belonged to Naresh.

The defence also contended that the proceedings had been initiated to harass him. It referred to communications and proposed interactions between the parties after the complaint had been filed, arguing that these circumstances supported its position.

Another argument concerned the bank account into which the money had allegedly been deposited. The defence submitted that the account was an online account and that the complainant had deliberately deposited money into it.

The order records that the court considered this explanation but found no material in the case file showing that Naresh had attempted to return the amount on the basis that it had been deposited without his consent or had arrived inadvertently.

The defence further submitted that Naresh was cooperating with the investigation and that his arrest was not necessary. It stated that he was prepared to comply with any conditions imposed by the court if anticipatory bail were granted.

The defence also informed the court that a Delhi court had granted him transit bail protection until 4 p.m. on October 27, 2026. That temporary protection was distinct from the regular anticipatory bail application subsequently decided by the Jaipur court.

Despite these submissions, the court concluded that the circumstances and material available at that stage did not justify granting anticipatory bail.

Delhi High Court Proceedings Also Find Mention in the Order

The Jaipur court’s order refers to three proceedings before the Delhi High Court: CS (OS) Nos. 756/2026, 815/2026 and 297/2026.

According to the account contained in the Jaipur order, directions had been passed in these proceedings restricting Naresh and others from publishing certain articles of the kind described in the orders as having the effect of preventing the complainant from exercising his legal rights.

The Jaipur court considered these proceedings relevant to understanding the background to the dispute between the parties over publications and communications.

The order describes the underlying disagreement as one involving adverse articles and related communications. It then distinguishes the criminal case before it, which concerned allegations that money had been demanded in exchange for refraining from further publications or communications.

The reference to the Delhi High Court proceedings does not, by itself, establish that the alleged extortion took place. Rather, the Jaipur court considered the existing dispute and the related judicial proceedings alongside the material presented in the criminal investigation.

The precise scope and terms of the Delhi High Court’s directions would be governed by the respective orders passed in those cases.

Alleged Threat Against the Complainant’s Advocate

Another circumstance specifically noted in the Jaipur order concerns an alleged incident on October 26, 2026.

The court recorded that, according to the case diary, an allegation had been made that Naresh threatened the complainant’s advocate outside the court premises. The order identifies the advocate as Garvit Khandelwal and records that a report against Naresh was lodged at Sadar Police Station, Jaipur, on the same date.

This incident was referred to as part of the material reflected in the case diary when the court assessed the surrounding circumstances.

The reference must be understood in its proper procedural context. The order records the allegation and the lodging of a police report; it does not constitute a separate final finding that the alleged threat has been proved.

Nevertheless, the court took account of the material before it as part of its overall consideration of whether pre-arrest protection was warranted.

Court Finds That Further Investigation Remains Necessary

After considering the arguments and examining the case diary and the material collected during the investigation, the court concluded that the dispute between the parties extended beyond a disagreement over published articles.

The order records that the complainant’s case involved alleged demands for money accompanied by threats of further adverse publications, and that a payment of ₹11,700 appeared, at first instance, to have been deposited into the account identified in the proceedings as belonging to Nine Network Private Limited.

The court acknowledged the defence explanation concerning the account and the alleged deposit. However, it observed that the case file contained no material showing an attempt by Naresh to return the money on the basis that it had been deposited inadvertently.

The court further observed that, according to the investigation conducted up to that stage, material was available supporting the allegations under the relevant provisions of the Bharatiya Nyaya Sanhita. It also noted that investigation remained pending.

The distinction is important: the court was not conducting a criminal trial or finally deciding whether every element of the alleged offences had been established beyond reasonable doubt. It was determining whether the circumstances justified granting anticipatory bail while the investigation was ongoing.

In reaching its decision, the court considered the nature and seriousness of the allegations, the material then available and the continuing requirement of investigation.

Supreme Court Precedents on Anticipatory Bail Considered

The order discusses the principles governing anticipatory bail and refers to judicial precedents cited during the proceedings.

Among the authorities relied upon by the court was the Supreme Court’s decision in Pratibha Manchanda and Others v. State of Haryana and Others, reported in (2023) 8 SCC 181. As set out in the order, the relevant considerations include the accused’s liberty and presumption of innocence, the seriousness of the alleged offence, its potential impact on society and the need to ensure a proper investigation.

The court also referred to State of Madhya Pradesh v. Pradeep Sharma, reported in AIR 2014 SC 626, while discussing the exceptional nature of anticipatory bail under the corresponding provision of the former Code of Criminal Procedure.

A further reference was made to Pankaj v. State of Rajasthan, reported in 1996 Cri. L.J. 3265, in connection with the principle that anticipatory bail should be considered in the context of the particular circumstances and the possibility of false implication.

The defence had cited several judicial decisions in support of its request for protection. The complainant’s counsel and the prosecution, on the other hand, opposed the application, relying on the allegations, the documents placed before the court and the need for further investigation.

After considering the competing submissions and the judicial authorities, the court found that the case did not fall within the category of exceptional circumstances warranting anticipatory bail.

Why the Court Rejected the Application

The court’s decision rested on an assessment of the circumstances collectively rather than on any single factor in isolation.

The order identifies several considerations that weighed against granting relief: the allegations of repeated monetary demands and threats of further adverse publications; the emails dated August 26 and September 3, 2026, relied upon by the complainant; the documentation concerning the ₹11,700 deposit; the absence of material showing that the amount had been returned or that an effort had been made to return it; the related proceedings concerning publications before the Delhi High Court; and the fact that investigation remained incomplete.

The court also referred to the alleged incident involving the complainant’s advocate on October 26, 2026, as recorded in the case diary.

Having considered the nature of the allegations, the material collected and the outstanding investigation, the court held that granting anticipatory bail would not be justified in the circumstances.

The order did not purport to finally determine the merits of the criminal case. Instead, it decided the narrower question of whether Naresh should receive protection against arrest at the anticipatory bail stage.

Anticipatory Bail Plea Formally Dismissed on October 28

In the operative portion of the order, the court rejected and dismissed the anticipatory bail application filed by Nitin Naresh under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023.

The order was pronounced on October 28, 2026, by Additional Sessions Judge No. 7, Jaipur Metropolitan-II, Renuka Singh Hudda, RJS.

The dismissal means that the particular application for anticipatory bail was not granted. The court did not issue an order in this proceeding finally convicting Naresh of extortion or any other offence.

The criminal investigation and any subsequent legal proceedings must proceed in accordance with law, with the allegations ultimately to be assessed through the applicable judicial process.

A Significant Development in the Criminal Proceedings

The rejection of the anticipatory bail application marks a significant procedural development in FIR No. 267/2026. The Jaipur court’s order sets out the allegations concerning the emails, the demand for money, the bank deposit and the dispute over further publications, while also recording the defence’s denial and its objections to the prosecution’s case.

The court’s central conclusion was that, in light of the material available at that stage and the need for further investigation, the circumstances did not warrant extending anticipatory bail protection.

The matter now remains subject to the further course of the criminal proceedings. Any ultimate determination of guilt will depend on the evidence and the findings reached through the legal process.

Editorial note: This article is based on the order dated October 28, 2026, passed by the Court of Additional Sessions Judge No. 7, Jaipur Metropolitan-II, in Anticipatory Bail Application No. 358/2026. The allegations described are not a substitute for proof at trial, and the rejection of anticipatory bail must not be represented as a criminal conviction.