This judgment deals with successive PMLA bail under Article 21 despite Section 45 twin conditions due to delayed predicate offence trial.

Case Snapshot

• Case Name: Rohan Rangnathan Harmalkar v. Directorate of Enforcement

• Citation / Neutral Citation: 2026:BHC-GOA:1933

• High Court: Bombay High Court at Goa

• Bench: Justice S.G. Chapalgaonkar

• Date of Judgment: September 29, 2026

• Area of Law: PMLA bail; Section 45 twin conditions; Article 21 speedy trial; prolonged incarceration

Judgment Headline

Bombay HC Grants Bail in PMLA Case Due to Delayed Predicate Offence Trial

The Judgment in One Line

Bombay High Court granted bail in a PMLA case despite Section 45 twin conditions, citing over 15 months’ incarceration and no possibility of trial due to delayed predicate offence chargesheet.

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