PMLA bail turns on prima facie assessment, not a mini trial, where a chartered accountant's role needs trial examination.

At the bail stage in a PMLA prosecution, the Court applied a prima facie assessment on broad probabilities rather than a conclusive determination of guilt, and held that a special statute bail hearing cannot become a mini trial. The allegation was that a chartered accountant aided laundering by filing returns and handling financial matters, but the Court found that his role and whether he acted beyond professional instructions required trial-level examination. On the record then available, the Court granted bail subject to conditions.

---

---

Issues: Whether bail should be granted in a prosecution under the Prevention of Money Laundering Act, 2002 where the allegation was that the petitioner, a chartered accountant, had aided the laundering process by filing returns and handling financial matters.

Analysis: The material was assessed at the bail stage on the standard of broad probabilities and prima facie satisfaction, not on a conclusive determination of guilt. The Court noted that in special statute bail matters, the issue is whether the accused appears unlikely to be guilty on the record presently available and whether release is likely to prejudice the process of justice. The petitioner's role was stated to be confined to professional work performed as a chartered accountant, and the larger question whether he acted beyond the scope of professional instructions was held to require examination at trial. The Court also held that a bail hearing cannot become a mini trial or require detailed appreciation of evidence.

Conclusion: Bail was granted to the petitioner, subject to conditions.

Ratio Decidendi: At the stage of bail under a special statute, the Court applies a prima facie assessment on broad probabilities and does not conduct a mini trial; allegations against a professional functionary must be tested at trial if the record does not clearly establish culpable participation.

---