Youth Entrapped in Digital Seduction—Not a Spy with Malicious Intent: Bombay High Court Grants Bail in Naval Dockyard Espionage Case

“This is a classic case of honey trap—Young minds must beware of flattery from strangers on social media,” - Bombay High Court granted bail to Gaurav Arjun Patil, a 23-year-old former apprentice at the Naval Dockyard, Mumbai, who was accused of leaking sensitive naval information to suspected foreign agents posing as social media friends. The Court, while deciding Criminal Bail Application No. 2893 of 2024, observed that “this is a classic case of honey trap,” and emphasized that the youth must remain vigilant against online seduction and emotional manipulation tactics often used by foreign intelligence operatives. 
Justice Milind N. Jadhav, after a detailed 30-page judgment, granted bail under Section 439 CrPC, despite serious charges under Sections 3, 4, 5, and 9 of the Official Secrets Act, 1923, and Section 120-B IPC, observing that:  “Prima facie, the applicant was lured and manipulated into giving limited information without understanding its implications. There is no conclusive proof that he knowingly shared classified material.”
“The accused was a 21-year-old apprentice with no prior record – his continued incarceration risks turning him into a hardened criminal” 
The Court emphasized a reformative, rather than retributive, approach and relied upon penological principles favoring rehabilitation of young offenders: “The applicant is at the threshold of his adult life. Incarceration for an uncertain period would derail his future prospects and potentially push him toward criminality.” 
Drawing on the Probation of Offenders Act and global jurisprudence, the Court stressed that young, first-time offenders deserve a second chance—particularly when manipulation and seduction tactics are involved. 
“Evidence suggests a covert operation of seduction-based espionage through social media” The Court expressed judicial alarm over the modus operandi of the co-accused (Accused Nos. 2 and 3), stating:   “Honey trap is a social media-enabled crime wherein fake profiles are created with attractive images to manipulate unsuspecting targets into disclosing sensitive information.” 
“Prima facie, the applicant fell prey to this psychological operation over months of emotional manipulation and false intimacy. Youth must beware of unsolicited, flattering messages from strangers on social media.” 
“Information Shared Was Not Clearly Classified or Sensitive—Nature and Classification Are Triable Issues” 
On the nature of the alleged disclosures, the Court noted: “Applicant shared names of naval ships docked for repairs and one engine drawing, which was part of his academic training. No wilful breach of official secrets is prima facie evident.” The chats showed that the applicant often refused to share information, questioned the queries, and even suggested that the co-accused look up the details on Google, indicating a lack of conspiratorial intent. 
“Full Cooperation with Authorities—No Tampering, No Destruction of Evidence” 
The Court was significantly persuaded by the applicant’s conduct during the investigation:  “The applicant did not delete any chats, voluntarily provided his Facebook credentials, and surrendered his phone—conduct reflective of bona fides.” 
The entire chat history, which forms the backbone of the prosecution’s case, was retrieved in full, supporting the applicant’s claim of transparency. 
“Sixteen Months in Jail Without Trial—Applicant Not in Service Anymore, No Risk of Reoffending” 
The applicant has been in custody since December 13, 2023. Noting that trial has not yet begun, and he no longer has access to sensitive areas of the Dockyard, the Court held:  “There is no likelihood of the accused repeating the offence or tampering with evidence. His phone and devices are already in custody.” 
Court’s Concluding Reflection: “Youth Must Be Alert – Social Media Can Be a Weapon in the Hands of Espionage” 
Delivering a stern societal warning, the Court stated:  “Purpose of the bail court is also to caution the society, especially the youth, who are overly exposed to the digital world, lest they get trapped in unwanted and irreversible situations like the applicant.” 
The Court emphasized the need for cyber vigilance, particularly in defense establishments, and called for awareness campaigns on seduction-based espionage. 
Date of Decision: April 15, 2025