PMLA bail granted after prolonged custody, prior summons compliance, and no arrest during investigation.

In a prosecution under the Prevention of Money-Laundering Act, 2002, bail was found justified where the applicant had already spent more than four years in custody, had earlier appeared before the Enforcement Directorate on summons without arrest under Section 19, and the complaint had been filed and cognizance taken without any custody request. The Court treated the substantial custody period, the seven-year maximum sentence, and the unlikely early conclusion of trial as satisfying the statutory rigours for bail, and the applicant was ordered to be released on bail.

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Issues: Whether the applicant was entitled to bail in a prosecution under the Prevention of Money-Laundering Act, 2002 in view of the period of custody already undergone, the manner in which the Enforcement Directorate had earlier proceeded without arrest, and the applicability of the statutory rigours governing bail.

Analysis: The complaint under the Prevention of Money-Laundering Act, 2002 arose from the predicate offence, and the applicant had already been in judicial custody in the predicate case for a substantial period. The applicant had appeared before the Enforcement Directorate on summons, recorded his statement, and had not been arrested under Section 19 of the Prevention of Money-Laundering Act, 2002 when the investigation was underway. The prosecution complaint had been filed and cognizance taken without any request for custody at that stage. The Court noted that the applicant had undergone more than four years of incarceration, that the maximum sentence under the Act is seven years, and that the trial was not likely to conclude expeditiously. Relying on the principle that stricter statutory rigour must be matched by quicker adjudication, the Court held that the requirements for grant of bail stood satisfied.

Conclusion: Bail was deserved and the applicant was entitled to release on bail.

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