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Supreme Court of India · 06/01/2026

ARVIND DHAM versus DIRECTORATE OF ENFORCEMENT

[2026] 1 S.C.R. 119 · 2026 INSC 12

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Summary

The Court granted regular bail to the appellant, a former promoter of the Amtek group, in a money-laundering prosecution, holding that about 16 months of custody with no cognizance yet taken, investigation against him concluded, largely documentary evidence and no early prospect of trial violated his right to a speedy trial under Article 21, despite the twin conditions in Section 45 PMLA.

Issues

  1. Whether prolonged pre-trial custody without likelihood of early trial entitles an accused under the PMLA to bail notwithstanding Section 45.
  2. Whether economic offences can be treated as a single class warranting denial of bail.
  3. Whether the allegations of influencing a witness and dissipating attached properties justified continued custody.

Provisions considered

Held

Result

Appeal allowed; High Court's order of 19.08.2025 set aside; appellant to be released on bail pending trial on terms fixed by the trial court, and additionally to furnish a contact number to the Directorate, surrender his passport and not leave India without the trial court's permission.

Judgment PDF: Supreme Court of India, [2026] 1 S.C.R. 119.