PMLA arrest compliance: oral communication of grounds and next-working-day transmission satisfied statutory requirements on the facts.

Under Section 19 of the Prevention of Money-Laundering Act, 2002, the validity of arrest turned on communication of the grounds of arrest and prompt forwarding of arrest material to the Adjudicating Authority. The Court stated that the Supreme Court's requirement in Pankaj Bansal to furnish grounds in writing applied prospectively and did not control an arrest made on 09.06.2023; at that time, oral communication remained legally sufficient. On the facts, the contemporaneous record, signatures on the grounds document, witness countersignatures, and connected remand papers supported compliance. Transmission to the Adjudicating Authority on the next working day after a Friday night arrest was treated as sufficient immediacy.

---

---

Issues: Whether the arrest of the petitioner was illegal for alleged non-compliance with Section 19 of the Prevention of Money-Laundering Act, 2002, particularly on the questions whether the grounds of arrest had been sufficiently communicated and whether the arrest order and connected material were forwarded to the Adjudicating Authority in accordance with law.

Analysis: The Court held that the requirement to furnish the grounds of arrest in writing, as laid down by the Supreme Court in Pankaj Bansal, operated prospectively and did not govern an arrest made on 09.06.2023. At the relevant time, the governing law permitted oral communication of the grounds of arrest, and the earlier view sustaining such compliance continued to hold the field until it was overruled. On the facts, the contemporaneous record showed that the petitioner had been shown the grounds of arrest, had signed the document, and the same was countersigned by independent witnesses. The remand application, remand orders, panchnama, arrest memo, and arrest order supported that conclusion, and the Court applied the presumption that official acts are regularly performed. As regards forwarding the arrest order and material to the Adjudicating Authority, the Court held that transmission on the next working day after a Friday night arrest satisfied the statutory requirement of immediacy in the circumstances.

Conclusion: The arrest was not held illegal, and the challenge based on Section 19 of the Prevention of Money-Laundering Act, 2002 failed; the proceedings were dismissed in favour of the Revenue.

---