Pre-trial bail under PMLA may be justified when trial is at an early stage and custody has already become prolonged.

In a prosecution under the Prevention of Money Laundering Act, 2002, pre-trial detention was held unjustified where the trial had barely begun, only the examination-in-chief of the first witness had been completed, and several witnesses remained to be examined. The Court treated the appellant's long custody, the likelihood of a prolonged trial, the attachment of properties, and the deposit of the passport as adequate safeguards against absconding or dissipation of assets. On that basis, continued incarceration was found unnecessary for securing the ends of justice, and bail was granted by setting aside the earlier refusal.

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Issues: Whether the appellant was entitled to bail pending trial in a prosecution under the Prevention of Money Laundering Act, 2002, having regard to the stage of the trial and the length of custody.

Analysis: The prosecution had not progressed beyond the examination-in-chief of the first witness, while several witnesses still remained to be examined and the trial was likely to take considerable time. The appellant had been in custody for a substantial period, his properties remained attached, and his passport had already been deposited with the investigating agency. In these circumstances, continued detention was found unnecessary for securing the ends of justice, and sending the parties back for another bail round was considered unwarranted.

Conclusion: The appellant was entitled to bail and the earlier refusal of bail was set aside.

Ratio Decidendi: Where the trial is at a rudimentary stage, custody has already continued for a long period, and adequate safeguards exist to secure attendance and prevent dissipation of property, continued pre-trial detention may be unjustified and bail may be granted.

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