Regular bail in a serious economic offence was refused because multiple pending cases triggered a statutory bar despite prolonged custody.

Regular bail in a PMLA matter was declined where the accused faced a serious economic offence, was alleged to have played a central role in preparing and manipulating documents, and was already involved in multiple connected ECIR proceedings. The Court treated prolonged custody as insufficient on its own to justify release, given the gravity of the accusations, the pending trial, and the concern that delay was being aggravated by repeated petitions. Section 479 of the Bharatiya Nagarik Suraksha Sanhita, 2023 was considered, but its sub-section (2) was read as barring release where multiple cases or offences remained pending against the same person. Authorities cited for custody-based bail relief were distinguished.

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Issues: Whether the petitioner was entitled to regular bail in a PMLA case on the ground of prolonged custody and pending trial, and whether Section 479 of the Bharatiya Nagarik Suraksha Sanhita, 2023 permitted release despite multiple pending cases.

Analysis: The petitioner had already been denied bail in the present matter and in connected ECIR proceedings. The allegations involved a serious economic offence with a key role attributed to the petitioner in preparation and manipulation of documents. The Court considered the principles governing bail in serious economic offences and noted that custody by itself does not override the overall circumstances, including the gravity of accusation, the petitioner's involvement in multiple ECIR cases, and the likelihood that the delay in trial was being contributed to by accused persons through repeated petitions. Section 479 of the Bharatiya Nagarik Suraksha Sanhita, 2023 was examined, but sub-section (2) was found to bar release on bail where multiple cases or offences were pending against the same person. The authorities relied upon by the petitioner were distinguished on the ground that they did not involve the same multiple-case situation.

Conclusion: The petitioner was not entitled to regular bail and the prayer for bail was rejected.

Final Conclusion: Prolonged custody did not outweigh the gravity of the economic offence and the statutory bar arising from multiple pending cases, so no bail relief was granted.

Ratio Decidendi: In a serious economic offence, regular bail may be declined where the accused is involved in multiple pending cases and the applicable statutory framework bars release notwithstanding custody-based claims.

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