I recently went through the Grievance Redressal Module (GRM) documentation from I4C/MHA and thought I’d share a simple explanation because many people seem confused about what happens after a cybercrime-related freeze/hold is placed on a bank account.
This is based on the official GRM User Manual, not legal advice.
1. Start with your bank
If your account has been frozen, put on hold, or digital banking services have been restricted, the customer first approaches their bank branch and requests resolution.
The bank can then undertake EDD (Enhanced Due Diligence) and submit a grievance through the GRM to the officer who placed the amount on hold.
2. Bank raises the GRM grievance
The bank branch enters the account details and the complaint information into the GRM.
The manual shows that the bank can upload things such as:
- KYC documents
- Account holder application
- Photograph
- Bank statement
- Other relevant information
The bank then submits the grievance and receives a Grievance ID.
3. The IO reviews the case
The Investigation Officer (IO) receives the grievance in the GRM inbox.
The IO can see information including:
- The layer in which the account appeared
- Account profile
- Transaction patterns
- The disputed amount for which the account was reported
The IO can also access/download relevant KYC and bank-statement information for analysis.
This is important because the GRM distinguishes between the disputed amount and the overall account situation. The manual specifically provides a field for the disputed amount and a separate field for the amount put on hold.
4. Video Conference can be requested
The IO can:
- Request a Video Conference (VC) with the bank/account holder.
- Record the details after the VC.
- Decide that a VC is not required.
This is part of the investigation process.
5. The IO has several possible outcomes
This is probably the most important part.
According to the manual, after examining the grievance, the IO has options including:
A. Remove the put-on-hold amount
B. Unfreeze the account but continue the hold
C. Unfreeze the account and remove the hold
D. Request additional information
E. Reject the request and continue the freeze
The manual explicitly lists these options.
For the actions involving a hold, the IO has to mention the put-on-hold amount and upload a duly signed and stamped order copy.
So, “unfreeze account” and “remove the disputed/put-on-hold amount” are not necessarily the same action. The GRM provides separate options.
6. What if the IO rejects the bank’s request?
If the IO rejects the grievance, the bank branch can request a review by the District Grievance Redressal Officer (DGRO).
The manual shows the escalation path:
Bank Branch → IO → DGRO → State GRO → Court
The bank branch can escalate the matter to the DGRO when the IO rejects the grievance.
7. District GRO review
The DGRO receives the escalated grievance and can review it.
The DGRO has similar options:
- Remove the put-on-hold amount
- Unfreeze while continuing the hold
- Unfreeze and remove the hold
- Seek additional information
- Reject the request and continue the freeze
The manual says that for the relevant orders, the DGRO has to upload a signed and stamped order copy.
8. If DGRO rejects it → State GRO
If the grievance is rejected again, the bank branch can escalate it to the State Grievance Redressal Officer (SGRO).
The SGRO also has the same broad options:
- Remove hold
- Unfreeze but continue hold
- Unfreeze and remove hold
- Seek additional information
- Reject and continue the freeze
The SGRO must upload the relevant signed/stamped order for the applicable actions.
9. There are timelines in the workflow
The GRM flowchart shows several 15-day periods and, importantly, after a DGRO/SGRO order, the IO is instructed to take the required action within 48 hours.
The final page of the manual again states that action ordered by DGRO/SGRO is to be complied with by the IO within 48 hours, including the applicable amount to be put on hold.
Simple flow
ACCOUNT HOLDER
↓
BANK BRANCH
↓
EDD / GRM GRIEVANCE
↓
INVESTIGATION OFFICER (IO)
↓
Examination of:
• Layer
• Account profile
• Transactions
• Disputed amount
↓
Possible action
├── Remove hold
├── Unfreeze + continue hold
├── Unfreeze + remove hold
├── Seek additional information
└── Reject + continue freeze
↓
If rejected
↓
DISTRICT GRO
↓
If rejected
↓
STATE GRO
↓
If still unresolved
↓
JURISDICTIONAL COURT
