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Balancing Liberty And Enforcement: Bail Jurisprudence Under PMLA In V. Senthil Balaji (2024 INSC 739)




Dinesh Kumar T, Lovely Professional University, School of Law


ABSTRACT:


This case comment examines the Supreme Court’s decision in “V.Senthil Balaji v. Directorate of Enforcement(2024)”, a landmark ruling in India’s money laundering jurisprudence. The case concerned allegations of a large-scale recruitment scam and laundering of proceeds through complex financial transactions. While reaffirming the existence of a prima facie case under the Prevention of Money Laundering Act, 2002 (PMLA), the Court foregrounded Article-21’s guarantee of a speedy trial, holding that indefinite pre-trial incarceration cannot be justified under Section-45 stringent bail conditions. By granting bail subject to strict safeguards, the judgment reflects a nuanced balance between protecting the integrity of financial investigations and preventing the PMLA from becoming an instrument of pre-trial punishment. Doctrinally, the ruling tempers the rigidity of Vijay Madanlal Choudhary(2022) while resonating with the constitutional reasoning of Nikesh Tarachand Shah(2017). It strengthens judicial oversight of the Enforcement Directorate and recalibrates bail jurisprudence, ensuring that India’s fight against money laundering remains firmly anchored in constitutionalism.


Keywords: Money Laundering, Prevention of Money Laundering Act(PMLA), Bail Jurisprudence, Article 21-Speedy Trial.




Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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