PMLA bail refused where prima facie role in forged-document proceeds-of-crime chain outweighed reliance on cited precedents.

In a PMLA bail matter, the Court found prima facie material suggesting the petitioner's involvement in a forged-deed and land-record manipulation chain linked to proceeds of crime, and held that regular bail was not warranted. It distinguished the cited bail precedents as factually different, including cases lacking prima facie participation or involving a different statutory setting. The objection based on Section 19 of the PMLA was also rejected because the grievance had not been raised at the time of remand and was taken much later. On the facts and seriousness of the alleged offence, the bail application failed and custody continued.

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Issues: Whether the petitioner was entitled to regular bail in a prosecution under the Prevention of Money Laundering Act, 2002, and whether the plea based on non-disclosure of grounds of arrest and the cited precedents warranted release on bail.

Analysis: The allegations disclosed a coordinated money-laundering operation involving forged deeds, manipulation of land records, and alleged proceeds of crime, with material indicating the petitioner's role in the transaction chain and recovery of forged documents. The Court distinguished the cited decisions on bail, noting that those matters turned on materially different facts, including absence of prima facie material of participation, different statutory context, or special factual features. The objection based on Section 19 of the Prevention of Money Laundering Act, 2002 was not accepted, the Court noting that the grievance was not raised at the time of remand and was raised much later. Considering the seriousness of the alleged offence, the nature of the material collected, and the individual facts of the case, the Court held that the general principle that bail is the rule did not compel release here.

Conclusion: The petitioner was not entitled to regular bail.

Final Conclusion: The bail application failed and the petitioner remained in custody in connection with the PMLA proceedings.

Ratio Decidendi: In a money-laundering case, regular bail may be refused where the record discloses a prima facie role in a forged-document and proceeds-of-crime transaction chain and the cited precedents are factually distinguishable; the bail court must assess the case on its own merits rather than apply the general rule of liberty mechanically.

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