PMLA bail denied where prima facie material linked the accused to laundering activity despite prolonged custody and trial delay.

Regular bail under the Prevention of Money Laundering Act was refused because the Court found substantial prima facie material linking the applicant to the alleged laundering activity. The Enforcement Directorate's record, including statements, digital evidence and fund-flow material, indicated involvement in the liquor syndicate and alleged proceeds of crime, and the grounds of arrest had been given in writing. Although the applicant had been in custody for a significant period and the trial was unlikely to conclude soon, those factors did not outweigh the rigour of the statutory bail conditions. On that assessment, the applicant failed to satisfy the twin conditions for bail under Section 45 and the prayer was rejected.

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Issues: Whether the applicant was entitled to regular bail in a prosecution under the Prevention of Money Laundering Act, 2002, having regard to the rigour of the twin conditions under Section 45 of that Act, the material collected during investigation, and the plea of prolonged custody and delay in trial.

Analysis: The applicant sought bail in connection with alleged offences under Sections 3 and 4 of the Prevention of Money Laundering Act, 2002. The Court considered the material gathered by the Enforcement Directorate, including statements, digital evidence, flow of funds, alleged proceeds of crime, and the applicant's role in the liquor syndicate. It noted that, although the applicant had remained in custody for a significant period and the trial was not likely to conclude soon, the allegations disclosed a serious economic offence involving massive loss to the State exchequer. The Court further held that the circumstances showed substantial material connecting the applicant with the alleged laundering activity and that the grounds of arrest had been communicated in writing. On this prima facie assessment, the Court found that the applicant had not been able to satisfy the statutory conditions governing grant of bail under Section 45 of the Prevention of Money Laundering Act, 2002.

Conclusion: The applicant was not entitled to regular bail, and the bail prayer was rejected.

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