Medical bail and parity claims fail in PMLA case where custody treatment was available and prima facie material was serious.

Bail under Section 439 CrPC in a PMLA prosecution was declined where the applicant's medical condition was supported by ongoing treatment records and specialised care could be arranged in custody through the correctional home. The Court also found no basis for parity because the cited cases were materially different, and it considered the charge-sheet material, the applicant's role as a debenture trustee, and the stage of proceedings where charge had not yet been framed. Directions were issued for expeditious framing of charge and trial, as well as necessary medical care in custody.

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Issues: Whether the petitioner was entitled to bail under Section 439 of the Code of Criminal Procedure, 1973 on medical grounds and by parity, in a prosecution under the Prevention of Money Laundering Act, 2002.

Analysis: The petitioner relied on serious ailments and asserted that treatment in custody was inadequate. The Court noted, however, that the medical record showed continuing treatment and that urgent specialised treatment could be arranged through the correctional home at the cost of the Enforcement Directorate. The Court also considered the nature of the allegations under the Prevention of Money Laundering Act, 2002, the petitioner's role as a debenture trustee, the charge-sheet material, and the stage of the case when charge was yet to be framed. The request for parity was not accepted, as the material circumstances of the present case were found to be different from those cited. The Court further noted that the delay in trial was attributable in part to applications filed by the accused persons and directed expeditious framing of charge and trial.

Conclusion: Bail was refused, as no sufficient ground was made out for release on medical or parity grounds.

Final Conclusion: The application for bail failed, while directions were issued for expeditious progress of the trial and for necessary medical care of the petitioner in custody.

Ratio Decidendi: In a prosecution under the Prevention of Money Laundering Act, 2002, bail on medical grounds will not be granted where adequate specialised treatment can be arranged in custody and the case materials disclose a serious prima facie role in the laundering offence.

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