PMLA arrest compliance: written grounds on arrest date and reasoned remand sustain detention despite later forwarding of material.

Arrest under the Prevention of Money Laundering Act, 2002 was examined for compliance with Section 19. The written grounds of arrest were supplied on the date of arrest and acknowledged, satisfying the requirement that the arrestee be informed of the grounds and that reasons be recorded in writing. The remand court was found to have applied its mind to the arrest material and prima facie allegations, so the remand orders were not vitiated. Forwarding the arrest material to the Adjudicating Authority a day or two later under Section 19(2) did not, by itself, show non-compliance because same-day transmission is not a mandatory requirement.

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Issues: Whether the arrest complied with Section 19(1) of the Prevention of Money Laundering Act, 2002, and whether any infirmity in forwarding the arrest material under Section 19(2) or in the remand proceedings vitiated the detention.

Analysis: The petitioner's arrest was examined against the statutory requirements that the authorised officer must have material in possession, record reasons to believe in writing, and inform the arrestee of the grounds of arrest. The record showed that the written grounds of arrest were furnished on the date of arrest and acknowledged by signature. The Court also noted repeated non-appearance to summons, the surrounding circumstances relied upon by the investigating agency, and the special court's remand order, which reflected application of mind to the grounds of arrest and the prima facie allegations under the money-laundering provisions. As to Section 19(2), the Court held that forwarding the material to the Adjudicating Authority a day or two later did not by itself establish non-compliance, since the provision did not prescribe same-day transmission as a mandatory requirement.

Conclusion: The arrest was held to be in conformity with Section 19(1) of the Prevention of Money Laundering Act, 2002, and no illegality was found in the remand orders or the subsequent proceedings.

Ratio Decidendi: Where the written grounds of arrest under the Prevention of Money Laundering Act, 2002 are supplied and acknowledged on the date of arrest, and the remand court applies its mind to the record, the arrest satisfies Section 19 despite later forwarding of material to the Adjudicating Authority under Section 19(2).

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