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Issues: Whether the petitioner made out a case for grant of bail under the Prevention of Money Laundering Act, 2002, having regard to the statutory conditions under Section 45, the satisfaction of "reason to believe" under Section 19, and the plea of parity with a co-accused.
Analysis: The bail application was examined in the backdrop of the PMLA framework, including the nature of "proceeds of crime", the offence of money-laundering, the statutory presumption, and the mandatory bail restrictions. The material collected in investigation and in the complaint was relied upon to show that the petitioner was the beneficial owner and controlling mind behind the concerned company, that the transaction involved acquisition of property through allegedly forged and undervalued dealings, and that the petitioner's role was materially different from that of the co-accused who had been granted bail. The Court also considered that the twin conditions under Section 45 continue to govern bail under the Act and that parity cannot be claimed where the role and involvement are not .
Conclusion: The petitioner was held not entitled to bail. The conditions under Section 45 were found not satisfied, and the parity plea was rejected.
Ratio Decidendi: In a PMLA bail application, the Court must strictly apply the mandatory twin conditions under Section 45, and parity cannot be invoked where the applicant's role, control, and involvement in the alleged laundering activity are materially distinct from those of the co-accused.