District Judge R K Gauba dismissed the bail application of Pulkit Chaudhary saying the investigation was at initial stage and the accused does not deserve to be released on bail.
"At this stage the application cannot be allowed, hence the same is dismissed," the court said.
Police told the court that it was investigating the case in detail and more arrests are likely to be made in the case.
The police on December 4 had arrested five boys, including three law students, after a complaint was lodged at the Defence Colony police station in South Delhi on September 15 by the mother of the 16-year-old victim.
All the five accused including Chaudhary, Amandeep, Sharad Shekhar Tomar, Roopansu and Vikas Punia are presently lodged in Tihar jail.
The girl's mother had told the police that her daughter, who was studying in class XI, had not returned home after attending her school on September 15.
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Initially, a case of kidnapping was registered by the police but after the girl was recovered earlier this month, she deposed that on September 15 she had accompanied her friend Amit Gautam to his flat, where she was made captive and gangraped.
The victim had told the police that she had gone to Amit's flat in South Delhi to attend a party.
She had also said she came to know Amit through social networking site, Facebook, and they eventually became friends.
Chaudhary had reportedly threatened the girl to submit herself to him, claiming that he was a sub-inspector in Delhi Police.