Money-laundering bail requires satisfaction of twin conditions despite quashing of one predicate FIR and non-inclusion in its charge-sheet.

Regular bail in a money-laundering prosecution is discussed in relation to the continuing existence of a scheduled offence and the statutory twin conditions for release. The note states that quashing one EOW FIR and omission of the applicant from the predicate-offence charge-sheet did not negate the surviving scheduled offence or preclude money-laundering liability, which may extend to persons involved with proceeds of crime even if not accused in the predicate offence. It identifies Section 50 statements, witness material, allegedly forged reports, export documentation, invoices, adulteration allegations and company receipts as prima facie material. It also notes that detention duration and medical evidence did not justify bail, and reports refusal of regular bail.

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Issues: Whether the applicant satisfied the statutory conditions for regular bail in a money-laundering prosecution.

Analysis: The ECIR was founded on both the quashed EOW FIR and the surviving crime registered at Habibganj Police Station. The earlier coordinate-bench determination that the latter crime constituted a scheduled offence remained operative; therefore, the quashing of the EOW FIR and the applicant's absence from the police charge-sheet did not establish absence of a scheduled offence or exclude money-laundering liability. Money laundering concerns involvement in processes connected with proceeds of crime and may be independently prosecuted even where the person is not an accused in the predicate offence.

Analysis: Statements recorded under Section 50, witness material, forged laboratory reports, export clearances, false invoices, adulteration allegations, and receipts credited to the company provided prima facie material of the applicant's knowledge and involvement. The three-month detention after filing of the complaint did not demonstrate a violation of the right to expeditious trial. The medical material also did not establish sickness or infirmity warranting release. The applicant consequently failed to meet the twin conditions governing bail.

Conclusion: Regular bail was refused as the applicant was not shown to satisfy the statutory requirements for release in the money-laundering case.

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