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Issues: Whether the petitioner was entitled to regular bail under the Prevention of Money Laundering Act, 2002 and whether the statutory conditions for grant of bail were satisfied.
Analysis: The allegations arose from an Enforcement Directorate complaint based on suspected proceeds of crime connected with illegal mining, but the Court found that the petitioner was not named in the predicate FIR or the police report under Section 173(2) of the Code of Criminal Procedure, 1973. The investigation had been completed and the complaint had already been filed, reducing the need for further custodial interrogation. The Court also noted that the material suggested only assistance to the lease holder in mining-related work, with no direct allegation that the petitioner handled the finances of the alleged scheduled offence. The Court further considered that the petitioner had remained in custody for about five months, that the documents were already with the investigating agency, that the trial was likely to take time, and that the petitioner was receiving treatment for heart ailments.
Conclusion: The petitioner satisfied the conditions for bail under Section 45 of the Prevention of Money Laundering Act, 2002 and was entitled to release on regular bail.