PMLA bail principles applied on prima facie material, cooperation, and lack of role in disputed transactions; regular bail granted.

Regular bail under section 439 CrPC read with section 45 PMLA was granted because the material on record did not show the petitioner's operative role in the alleged transactions. The Court noted that the company through which transactions were routed did not involve the petitioner as director or shareholder during the relevant period, the disputed invoices were not shown to have been issued by him, and the bail inquiry remained a prima facie assessment on broad probabilities. It also considered cooperation with investigation, completion of the complaint, absence of demonstrated risk of tampering, and parity, and found the twin conditions under section 45 satisfied in the petitioner's favour.

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Issues: Whether regular bail should be granted to the petitioner under section 439 of the Code of Criminal Procedure, 1973 read with section 45 of the Prevention of Money Laundering Act, 2002, and whether the material on record satisfied the twin conditions applicable to bail under the PMLA.

Analysis: The alleged transactions were routed through a company in which the petitioner was neither a director nor a shareholder during the relevant period, and the Court found that the inward remittances did not require any operative act by the petitioner as recipient. The Court also noted that the petitioner was not shown to have issued the disputed invoices, while the outward remittances were made on instructions received through e-mails and the petitioner had no apparent financial stake in the transactions. Applying the PMLA bail standard, the Court held that the inquiry at the bail stage is only prima facie and on broad probabilities, without meticulous assessment of evidence, and that the Court must consider whether there are reasonable grounds to believe that the accused is not guilty and is unlikely to commit an offence while on bail. The Court further took into account the petitioner's cooperation with investigation, the completion of the complaint, the absence of demonstrated risk of tampering, and the relevance of parity in the factual setting.

Conclusion: The twin conditions under section 45 of the PMLA were found to be satisfied in favour of the petitioner, and regular bail was granted.

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