PMLA bail denied where prima facie material showed layering and concealment of proceeds of crime despite predicate offence objections.

Regular bail under the Prevention of Money-Laundering Act was refused because the material on record, including statements and diary entries, prima facie showed handling, layering, concealment and transfer of proceeds of crime, as well as acquisition of properties through unaccounted cash. The applicant failed to satisfy the Section 45 twin conditions requiring reasonable grounds to believe that he was not guilty and that he was not likely to commit an offence while on bail. The pending or unsettled state of the predicate offence did not displace the prima facie evidence of money-laundering involvement for bail purposes.

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Issues: Whether the applicant was entitled to regular bail in a prosecution under the Prevention of Money-Laundering Act, 2002, having regard to the rigour of Section 45 and the material indicating involvement in laundering of proceeds of crime.

Analysis: The applicant sought bail on the ground that investigation was complete and that the predicate offence was absent or not finalised. The Court noted, however, that the material placed on record, including statements and diary entries, prima facie indicated handling, layering, concealment, and transfer of proceeds of crime, as well as acquisition of properties through unaccounted cash. The Court further held that the applicant had not satisfied the statutory twin conditions under Section 45 of the Prevention of Money-Laundering Act, 2002, namely reasonable grounds for believing that he was not guilty and that he was not likely to commit any offence while on bail. The existence or state of the predicate proceedings did not displace the prima facie material of money-laundering involvement for the purpose of bail.

Conclusion: The applicant was not entitled to bail and the application was rejected.

Ratio Decidendi: In a bail application under the Prevention of Money-Laundering Act, 2002, the applicant must satisfy the twin statutory conditions under Section 45 on the basis of the material before the Court, and prima facie involvement in handling or layering proceeds of crime justifies of bail notwithstanding arguments on the predicate offence.

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