Former Bengal minister Sujit Bose denied bail in alleged recruitment-scam money-laundering case as probe into 45 properties continues

The petitioner, a former Minister and former Vice-Chairman of South Dum Dum Municipality, sought bail under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023, read with Section 45 of the Prevention of Money-Laundering Act, 2002 (PMLA).

The Enforcement Directorate (ED) arrested him on 11 May 2026 in an investigation concerning alleged laundering of proceeds generated through illegal municipal recruitments.

The petitioner argued, among other things, that the CBI’s predicate-case charge-sheets had not named him, that he had cooperated with the ED, and that the alleged financial transactions lacked a demonstrated connection to recruitment proceeds.

The ED relied on statements, digital records, alleged candidate recommendations, property transactions, cash deposits and corporate dealings, and opposed bail under Section 45.

The High Court noted that, while the supplementary prosecution complaint stated that investigation concerning the petitioner was complete, broader investigation continued.

It also recorded that, during August–September 2026, approximately 45 immovable properties connected to the petitioner and his family were identified through certified deeds, and that information had been shared with the CBI under Section 66(2) of the PMLA.

Whether the petitioner had satisfied the twin conditions for bail under Section 45 of the PMLA

Whether the continuing investigation, including the discovery of additional properties and information shared with the CBI, warranted refusal of bail at that stage

Section 45 of the PMLA imposes twin conditions for bail: the court must have reasonable grounds for believing that the accused is not guilty of the alleged offence and that the accused is not likely to commit an offence while on bail.

The Court relied on Union of India v. Kanhaiya Prasad, 2025 SCC OnLine SC 306, for the proposition that filing a prosecution complaint or taking cognizance does not, by itself, justify bail where the Section 45 conditions have not been met; courts must consider the statutory rigour and seriousness of the alleged money-laundering offence.

Section 66(2) of the PMLA was noted in connection with the ED’s sharing of information with the CBI.

The Court acknowledged the petitioner’s arguments concerning the delay in arrest, his exclusion from the CBI charge-sheets, the alleged absence of a financial trail, and the asserted lack of custodial necessity.

It nevertheless considered the ED’s account of newly identified immovable assets, the pending valuation exercise, further information about allegedly undeserving candidates, and the CBI’s commencement of further investigation to indicate that a vital investigative stage remained underway.

Applying Section 45 and Kanhaiya Prasad, the Court concluded that the petitioner had not overcome the statutory threshold for bail.

The judgment did not separately determine the petitioner’s challenge to the legality of his arrest.

C.R.M. (R) 58 of 2026 was dismissed, and any pending applications were disposed of.