PMLA bail restrictions upheld where prima facie laundering trail, non-cooperation, and flight risk justified refusal of relief.

Bail under the Prevention of Money Laundering Act, 2002 may be refused where the record discloses a prima facie laundering trail through layered transactions and corporate vehicles, and the statutory presumption and restrictive bail regime apply. Further investigation and a supplementary complaint were treated as permissible, and the accused's repeated non-appearance to summons, non-cooperation, and prior failed bail attempts weighed against discretionary relief. The seriousness of the allegations, together with the possibility of flight risk and tampering with evidence, supported rejection of bail.

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Issues: Whether bail ought to be granted to the petitioner in a prosecution under the Prevention of Money Laundering Act, 2002, having regard to the alleged money trail, the statutory restrictions on bail, the effect of further investigation and supplementary complaint, and the petitioner's conduct during investigation.

Analysis: The material on record was found to disclose a prima facie case of laundering of proceeds of crime through layered transactions and corporate vehicles. The offence of money laundering was treated as a distinct and continuing offence, and the Court applied the statutory presumption under the special law together with the restrictive bail regime. It was held that further investigation and a supplementary complaint were permissible, and that the petitioner's non-cooperation, repeated non-appearance to summons, and earlier unsuccessful bail attempts weighed against discretionary relief. In view of the seriousness of the allegations, the possibility of flight risk and tampering with evidence could not be ruled out.

Conclusion: Bail was refused and the application was rejected.

Ratio Decidendi: In a prosecution under the Prevention of Money Laundering Act, 2002, bail may be declined where the materials disclose a prima facie laundering trail, the statutory presumption applies, and the accused's conduct indicates non-cooperation or risk of absconding or interference with the investigation.

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