PMLA bail requires strict twin-condition scrutiny; parity fails where the accused's role and facts are materially different.

In bail matters under the Prevention of Money Laundering Act, the Court applied the mandatory twin conditions and the statutory presumption to hold that prima facie material, including statements under Section 50 and bank-account trails, was sufficient to deny regular bail. It treated money-laundering as independent of the predicate offence and held that completion of investigation or filing of complaint did not by itself justify release. The Court also rejected parity because a co-accused's bail does not create a right to similar relief where the petitioner's alleged role in procuring documents, preparing fake deeds, and receiving proceeds of crime was materially different.

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Issues: (i) Whether the petitioner made out a case for regular bail under the Prevention of Money Laundering Act, 2002 in view of the statutory twin conditions; (ii) Whether parity with a co-accused who had been granted bail entitled the petitioner to similar relief.

Issue (i): Whether the petitioner made out a case for regular bail under the Prevention of Money Laundering Act, 2002 in view of the statutory twin conditions.

Analysis: The material collected in investigation was treated as showing prima facie involvement of the petitioner in arranging blank pages, facilitating preparation and planting of fake deeds, and receiving funds linked to the alleged proceeds of crime. The Court applied the mandatory bail restriction under Section 45 of the Prevention of Money Laundering Act, 2002, along with the statutory presumption under Section 24, and held that the offence of money-laundering is independent of the predicate offence. The Court further held that statements recorded under Section 50 and the bank-account trail furnished relevant material at the bail stage and that completion of investigation or filing of complaint did not, by itself, justify release.

Conclusion: The petitioner failed to satisfy the twin conditions and bail was not warranted.

Issue (ii): Whether parity with a co-accused who had been granted bail entitled the petitioner to similar relief.

Analysis: The Court held that parity depends on identical or substantially similar and facts, and that a co-accused's bail does not create a right to similar relief where the individual role differs. The petitioner's alleged direct participation in procuring original volumes, assisting in fake deeds, and receiving proceeds of crime was found materially distinguishable from the co-accused relied upon for parity.

Conclusion: Parity was not available to the petitioner.

Final Conclusion: In the overall assessment, the allegations and materials were found sufficient at the prima facie stage to deny bail in an economic offence governed by stringent statutory conditions.

Ratio Decidendi: In bail matters under the Prevention of Money Laundering Act, 2002, the court must be satisfied, on a prima facie assessment, that the accused satisfies the mandatory twin conditions under Section 45, and parity can be invoked only where the accused's role and factual matrix are truly identical.

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