Medical bail under PMLA refused where stable chronic conditions and no need for specialised immediate treatment were shown.

Bail on medical grounds was refused under Section 439 CrPC read with the first proviso to Section 45(1) of the PMLA because the applicant failed to show a medical necessity for release. The Court relied on a specialist medical board report noting hypertension, controlled diabetes, bronchial asthma, obstructive sleep apnea and other chronic conditions, but finding the clinical condition stable on existing medication. It also accepted the prosecution's explanation on the disputed medical entries and found no material requiring immediate treatment from a particular doctor or hospital. The gravity of the allegations was also considered, and the request for bail was rejected.

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Issues: Whether the applicant was entitled to bail on medical grounds under Section 439 of the Code of Criminal Procedure, 1973 read with the first proviso to Section 45(1) of the Prevention of Money Laundering Act, 2002.

Analysis: The applicant relied on multiple ailments and questioned the authenticity of the medical reports. The medical board constituted by the Court, comprising specialists from several disciplines, found that the applicant was a known case of hypertension, controlled diabetes mellitus, bronchial asthma, obstructive sleep apnea and other chronic conditions, but that his clinical condition was stable with the medication already being given. The Court accepted the prosecution's explanation regarding the disputed medical entries and held that there was no material to show that immediate treatment from a particular doctor or hospital was medically necessary. The gravity of the allegations was also taken into account.

Conclusion: The applicant was not entitled to bail on medical grounds and the request was rejected.

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