PMLA bail requires satisfaction of twin conditions, and parity fails unless the accused's role is materially similar.

Under the Prevention of Money Laundering Act, 2002, regular bail depends on satisfaction of the mandatory twin conditions in Section 45, supported by a prima facie assessment of the accused's role. The Court examined investigation material, including statements and recovered documents, as indicating alleged involvement in preparing fake deeds, falsifying records, and dealing with proceeds of crime, and found no reasonable grounds to believe the petitioner was not guilty or would not reoffend on bail. Parity was also rejected because it turns on comparable role and factual involvement, not merely the grant of bail to a co-accused.

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Issues: (i) whether the petitioner was entitled to regular bail under the Prevention of Money Laundering Act, 2002 by satisfying the mandatory twin conditions; (ii) whether bail could be granted on the ground of parity with a co-accused.

Issue (i): whether the petitioner was entitled to regular bail under the Prevention of Money Laundering Act, 2002 by satisfying the mandatory twin conditions.

Analysis: The petition was considered in the light of the statutory scheme of money-laundering, including the definition of proceeds of crime, the offence under Section 3, the punishment under Section 4, the evidentiary value of statements recorded under Section 50, and the stringent bail restriction under Section 45. The material collected in investigation, including statements and recovered documents, was treated as prima facie showing the petitioner's role in preparing and using fake deeds, falsifying records, and handling proceeds of crime. The Court held that the petitioner had not shown reasonable grounds for believing that he was not guilty and had not satisfied the further requirement that he would not commit an offence while on bail.

Conclusion: The claim for regular bail failed on merits and was rejected.

Issue (ii): whether bail could be granted on the ground of parity with a co-accused.

Analysis: Parity was held to depend on similarity of role and factual involvement, not merely on the fact that another accused had obtained bail. On the materials placed, the petitioner's alleged role in preparing fake deeds and assisting in the acquisition and laundering of proceeds of crime was found distinguishable from the co-accused relied upon for parity.

Conclusion: Parity was not available to the petitioner.

Final Conclusion: The regular bail plea was declined because the statutory bail safeguards under the money-laundering law were not met and the plea of parity did not assist the petitioner.

Ratio Decidendi: In bail matters under the Prevention of Money Laundering Act, 2002, the Court must be satisfied on a prima facie basis that the accused satisfies the mandatory twin conditions under Section 45, and parity can succeed only where the role and factual involvement of the accused are materially similar.

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