PMLA arrest review requires manifest illegality or statutory non-compliance; prima facie proceeds-of-crime material sustained the arrest.

Arrest under the Prevention of Money Laundering Act was not shown to be vitiated by manifest illegality or non-compliance with statutory safeguards, as the record reflected recorded statements, search and seizure, communication of grounds of arrest, and production before the designated court. Prima facie material, including unaccounted cash, jewellery, digital material, and section 50 statements, was sufficient at the investigation stage to support involvement with proceeds of crime. The challenges based on earlier FIR arraignment, absence of quantification at arrest, and cooperation with investigation did not establish patent illegality, so the remand orders were upheld and writ interference was declined.

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Issues: Whether the petitioner's arrest under section 19 of the Prevention of Money Laundering Act, 2002 was illegal for want of statutory compliance and absence of material linking him to money laundering; and whether the remand orders deserved to be quashed.

Analysis: The statutory standard for judicial review of arrest under special enactments is limited to cases of manifest arbitrariness or gross non-compliance with the safeguards prescribed by law. The record showed recording of statements, search and seizure operations, communication of grounds of arrest and reasons to believe, production before the designated court, and successive remand orders. The material relied upon by the enforcement authority included unaccounted cash, diamond-studded jewellery, digital material, statements under section 50, and an explanation that the alleged bribe-related receipts constituted proceeds of crime. The Court held that the definition of proceeds of crime is broad, that money laundering is an independent offence connected with the process or activity involving such proceeds, and that the existence of prima facie material at the stage of arrest is sufficient. The challenge based on lack of prior arraignment in the earlier FIRs, alleged absence of quantification at the time of arrest, and reliance on cooperation with investigation did not establish patent illegality.

Conclusion: The arrest was held to be valid and the challenge to the remand orders failed.

Final Conclusion: The petition was found to be devoid of merit, with no ground made out for writ interference, while leaving the parties free to pursue their remedies in the appropriate forum.

Ratio Decidendi: Interference with an arrest under the Prevention of Money Laundering Act, 2002 is warranted only on manifest illegality or non-compliance with statutory safeguards, and prima facie material showing involvement with proceeds of crime is sufficient to sustain the arrest at the investigation stage.

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