Last updated: 23 September 2026. Every count re-pulled from the eCourtsIndia index on this date, the Enforcement Directorate figure corrected, and a new section added on the 2023 and 2024 Supreme Court rulings that changed how PMLA bail works in practice.
Bail under the Prevention of Money Laundering Act, 2002 (PMLA) is still governed by the twin conditions in Section 45, which the Supreme Court upheld in Vijay Madanlal Choudhary v. Union of India in July 2022. But the law on the ground has moved since then. Between October 2023 and September 2024 the Court required written grounds of arrest (Pankaj Bansal), held that long custody without trial can justify bail despite Section 45 (Manish Sisodia, V. Senthil Balaji), and restated that bail is the rule even under PMLA (Prem Prakash).
On the data side, the eCourtsIndia full-text index returns 12,003 case records that mention the PMLA, of which 2,092 also mention Section 45. Litigant records naming the Enforcement Directorate (ED) come to about 27,000. This post walks through those numbers, what they do and do not show, and the four rulings every PMLA bail application now leans on. Every figure links to a live search you can re-run on ecourtsindia.com.
Key takeaways
- Section 45 of the PMLA still bars bail unless the court finds reasonable grounds to believe the accused is not guilty and will not offend on bail. Read the text on IndiaCode.
- Since 2023 the Supreme Court has softened how those conditions apply: written grounds of arrest are mandatory, and prolonged custody with no trial in sight is now a recognised ground for bail.
- The index holds 12,003 PMLA records, 85% of them disposed. The Supreme Court alone accounts for 902.
- One district court complex, the Ranchi civil courts in Jharkhand, holds 7,499 of those records. The 2022 to 2024 “surge” in the data is mostly that one special court, so read national trends with care.
- The ED appears as a party in about 27,000 records, not the 2.66 lakh this post once claimed. Lucknow’s special court alone holds 6,900+ of them, mostly property-attachment applications filed in 2024 and 2025.
Section 45 in one paragraph
Section 45 of the PMLA says a person accused of money laundering cannot be released on bail unless the Public Prosecutor has been heard and, if the prosecutor opposes, the court is satisfied there are reasonable grounds for believing the accused is not guilty and is not likely to commit an offence while on bail.
These are the “twin conditions”. They flip the ordinary starting point of criminal procedure, where bail is the rule and jail the exception, and put the burden on the accused at the bail stage. The full text, with the provisos for women, minors and the sick or infirm, is on the IndiaCode page for PMLA Section 45. The arrest power that feeds into it sits in Section 19.
The history matters. In Nikesh Tarachand Shah v. Union of India (2018) 11 SCC 1, the Supreme Court struck down the twin conditions as they were then worded. Parliament re-enacted them through the Finance Act, 2018. On 27 July 2022, a three-judge bench in Vijay Madanlal Choudhary v. Union of India (2022 SCC OnLine SC 929) upheld the amended Section 45, along with the ED’s powers of arrest, search and attachment. The Court later agreed to hear a review limited to two points, supply of the ECIR and the reverse burden of proof. For most trial courts, though, Choudhary became the default frame for every PMLA bail hearing.
The rulings that changed PMLA bail after 2022
If you only read Choudhary, you would conclude that PMLA bail is close to impossible before trial. Four Supreme Court decisions between October 2023 and September 2024 changed that picture. Each is in the eCourtsIndia index with its CNR, so you can open the case record and read the orders.
| Case | Date | What it held | Case record |
|---|---|---|---|
| Pankaj Bansal v. Union of India, Criminal Appeal | 3 Oct 2023 | The ED must give the arrested person the grounds of arrest in writing, as a matter of course. Oral communication is not enough. Applies to arrests after the date of the judgment. | SCIN010302752023 |
| Manish Sisodia v. Directorate of Enforcement, Crl. A. 3295/2024 | 9 Aug 2024 | After 17 months in custody with the trial not begun, bail granted. The right to a speedy trial under Article 21 is read into Section 45; bail cannot be withheld as punishment. | SCIN010292662024 |
| Prem Prakash v. Union of India through the ED, Crl. A. 3572/2024, 2024 INSC 637 | 28 Aug 2024 | “Bail is the rule, jail the exception” applies to PMLA too. Section 45 restricts bail but is not an absolute bar; the discretion stays judicial. Bail granted. | SCIN010156082024 |
| V. Senthil Balaji v. The Deputy Director, ED, Crl. A. 4011/2024, 2024 INSC 739 | 26 Sep 2024 | Where the trial is unlikely to finish in a reasonable time and custody is long, constitutional courts can grant bail notwithstanding Section 45. Bail granted on strict conditions. | SCIN010127212024 |
Read together, these cases do not overrule Choudhary. The twin conditions are still law. What changed is the route around them. A defence lawyer now has three arguments that did not carry the same weight in 2022: a defective arrest (no written grounds), unreasonable delay in trial, and the general principle that Section 45 limits discretion without removing it.
The delay argument is the one that matters most in practice. PMLA prosecutions depend on a scheduled offence, often investigated by another agency, and the two tracks rarely move together. That is why Sisodia and Senthil Balaji turned on how long the accused had been in custody and how many witnesses were still to be examined, not on the merits of the money-laundering charge.
Lawyers who want the text of these orders can open each case record from the table above. With the AI Clerk, an AI summary of a long bail order costs Rs 2, which helps when you are reading twenty High Court orders that cite Prem Prakash to see how they applied it.
The PMLA universe, in numbers
Here is what the eCourtsIndia index returns today. These are full-text counts over case metadata and the text of uploaded orders, so a record appears if the term appears anywhere in it.
| Search | Records | Re-run it |
|---|---|---|
| “PMLA” anywhere in the record | 12,003 | search?q=PMLA |
| PMLA plus the phrase “Section 45” | 2,092 | search |
| PMLA records filed as Bail Applications (BA) | 371 | search |
| PMLA records filed as Anticipatory Bail Applications (ABA) | 165 | search |
| PMLA records in the Supreme Court | 902 | cc=SCIN01 |
Two caveats before anyone quotes these numbers. First, the April 2026 version of this post reported 14,134 PMLA records. Today’s figure is 12,003. The drop reflects index clean-up (duplicate and mis-tagged records removed), not fewer cases. Second, dedicated bail applications look small (536 BA and ABA together) because most PMLA bail litigation is filed under other case types: criminal miscellaneous petitions, writs and appeals. A case-type label tells you how a registry filed it, not what was argued.
Status split
| Status | Records | Share |
|---|---|---|
| Disposed | 10,227 | 85.2% |
| Pending | 1,025 | 8.5% |
| Other recorded stages (admitted, dismissed, hearing, allowed and others) | 751 | 6.3% |
| Total | 12,003 | 100% |
A high disposed share looks reassuring, but most of it is the bail and procedural layer. A bail plea, a writ against a summons or a quashing petition gets decided one way or the other. The PMLA prosecution itself, the complaint before the Special Court, can run for years after that. If you are tracking a specific matter, the Case Status Dictionary explains what each of the 71 status codes means.
Where the PMLA docket lives
| Court | Code | PMLA records | Re-run it |
|---|---|---|---|
| Civil Court Complex, Ranchi (Jharkhand) | JHRN01 | 7,499 | cc=JHRN01 |
| Supreme Court of India | SCIN01 | 902 | cc=SCIN01 |
| Bombay High Court (Principal Bench, Appellate Side) | HCBM01 | 485 | cc=HCBM01 |
| Delhi High Court | DLHC01 | 325 | cc=DLHC01 |
| Allahabad High Court (Lucknow Bench) | UPHC02 | 263 | cc=UPHC02 |
| Telangana High Court | HBHC01 | 205 | cc=HBHC01 |
| Madras High Court (Chennai) | HCMA01 | 203 | cc=HCMA01 |
| Karnataka High Court (Bengaluru) | KAHC01 | 185 | cc=KAHC01 |
The Ranchi figure stands out, and it deserves an honest explanation rather than a headline. The Ranchi civil court complex houses a Special Judge for PMLA cases, and its eCourts records carry PMLA references in the case category and the judge designation. That makes nearly every matter before that court show up in a PMLA search, including applications and sessions trials. Of its 7,499 records, 5,003 carry an unmapped case type and 2,279 are sessions trials. It is real data, but it reflects how thoroughly one court tags its records as much as where money-laundering litigation happens.
Outside Ranchi, the Supreme Court leads with 902 records. That is unusual. For most case types the apex court sits near the bottom of the volume table. PMLA is different because Section 45, the ED’s arrest powers and the Special Court procedure keep throwing up constitutional questions, and those travel to Delhi quickly. The Bombay and Delhi High Courts follow, which fits their place as the main financial-crime benches.
The filing-year pattern, and why Ranchi skews it
| Filing year | All PMLA records | Of which Ranchi (JHRN01) | Rest of India |
|---|---|---|---|
| 2018 | 311 | 45 | 266 |
| 2019 | 367 | 28 | 339 |
| 2020 | 340 | 32 | 308 |
| 2021 | 526 | 78 | 448 |
| 2022 | 2,240 | 1,674 | 566 |
| 2023 | 4,339 | 3,449 | 890 |
| 2024 | 2,651 | 1,864 | 787 |
| 2025 | 455 | 99 | 356 |
| 2026 (to 23 Sep) | 154 | 80 | 74 |
The earlier version of this table showed a smooth climb from about 750 filings in 2019 to about 3,800 in 2022. Those middle figures were estimates, and they were wrong. The real facet counts are above, and they tell a more careful story.
Take Ranchi out and PMLA filings roughly doubled between 2021 and 2023, from 448 to 890, then held near that level in 2024. The rise coincides with the period after Choudhary, but a filing count cannot prove the judgment caused it; ED case registration was already rising. The sharp spike in the headline column is mostly one court. And the low 2025 and 2026 numbers are largely a lag: district courts upload records and orders with a delay, so recent years fill in over time. Do not read 2025 as a collapse.
The Enforcement Directorate as a litigant
The ED shows up in court records under two main names. A litigant search for all the words “Enforcement Directorate” returns 26,955 records, which picks up both spellings. The exact phrase “Enforcement Directorate” returns 10,353 records and the exact phrase “Directorate of Enforcement” returns 16,305. The earlier figure of 2,66,583 in this post was wrong by a factor of about ten and has been removed. You can check the agency’s footprint through the litigant search.
| Where the ED appears | Records |
|---|---|
| District and Sessions Court, Lucknow (UPLK01) | 6,916 |
| Supreme Court of India | 2,261 |
| Delhi High Court | 1,986 |
| Bombay High Court (Principal Bench, Appellate Side) | 1,374 |
| Madras High Court (Chennai) | 733 |
| Punjab and Haryana High Court | 579 |
By state, Uttar Pradesh leads with 7,518 records, followed by Delhi (3,083), Maharashtra (2,727) and Tamil Nadu (1,869). The Uttar Pradesh number is almost entirely Lucknow. Of the 6,916 ED records there, 6,661 are criminal miscellaneous applications before the Special Judge (Anti-Corruption) West, and most were filed in 2024 and 2025. The ones with an act recorded cite PMLA Section 8, which deals with adjudication and confiscation of attached property. So the Lucknow block is mostly the ED’s property-attachment workload, not bail.
That also explains the ED’s filing-year curve: 1,347 records in 2021, 1,819 in 2022, 2,293 in 2023, then 5,951 in 2024 and 7,615 in 2025. Of the total, 14,056 are pending and 10,957 disposed. Anti-corruption matters often run in the same special courts; our guide to tracking Lokayukta and anti-corruption court cases shows how to find them.
Three older sample records, verified
A CNR (Case Number Record) is the 16-character alphanumeric code that identifies every case in the eCourts system. Paste any of these into eCourtsIndia to pull the full history. The CNR Number Decoded guide explains how to read one.
Supreme Court, filed 2015. Gautam Kundu v. Manoj Kumar, Assistant Director, ED, Criminal Appeal 1706/2015 (CNR SCIN010266742015). The Rose Valley matter. The Court applied Section 45 and upheld the refusal of bail. It was decided under the version of the section in force before the 2018 amendment and is still cited on the overriding effect of Section 45 over the CrPC. Disposed.
Delhi High Court, filed 2016, decided 2018. H.B. Chaturvedi v. Enforcement Directorate, Crl. M.C. 494/2016 (CNR DLHC010136602016). A petition challenging ED proceedings, disposed on 11 September 2018.
Bombay High Court, Nagpur Bench, filed July 2022. Shrikant Manohar Joshi v. Directorate of Enforcement, W.P. 573/2022 (CNR HCBM040166382022). A writ arising out of a PMLA proceeding, filed the same month Choudhary was decided. Still pending.
What this means for prosecution and defence
For the ED, the data shows an agency whose court footprint has grown sharply since 2021, with the biggest recent growth in attachment and confiscation work rather than bail. Prosecutors opposing bail still start from Section 45, but after 2024 they also have to answer the delay question: how long has the accused been inside, how many witnesses remain, and when will the trial realistically end.
For the defence, the practical checklist has changed. Was the arrest made with written grounds, as Pankaj Bansal requires? How long has custody run, measured against the likely trial length? Has the scheduled offence moved at all? These are the questions that decided Sisodia, Prem Prakash and Senthil Balaji, and they are questions court data can answer. A defence team can pull the hearing history of the Special Court case, count adjournments and show the pace of trial from the record itself.
For policy, the open question is whether Section 45 is still calibrated the way Parliament intended when the apex court keeps reading constitutional exceptions into it. The review of Choudhary on the ECIR and burden of proof may settle part of that. Until it does, the four rulings above are the working law. Other criminal-law posts in this series use the same method: see 498A by the Numbers and CrPC to BNSS mapping for bail and arrest.
Track a PMLA case yourself
- Search by party, CNR or case number on ecourtsindia.com/search. Search is free.
- Track the case and get WhatsApp or email alerts when a new order is uploaded (Rs 5 per case a month, Rs 0.50 per alert). See pricing.
- Read the statute alongside the orders on IndiaCode, which has all 81 PMLA sections.
- Check tomorrow’s Special Court listing in the free cause lists, or in the eCourtsIndia Chrome extension.
Replication and methodology
Every figure in this post comes from the eCourtsIndia index on 23 September 2026, using these calls. Headline universe: search_cases(query="PMLA") with facets on filingYear, caseStatus, courtCode and caseType. Section 45 slice: search_cases(query='PMLA "Section 45"'). Bail slice: search_cases(query="PMLA", caseTypes="BA,ABA"). Ranchi split: search_cases(query="PMLA", cc="JHRN01") with the filingYear facet. ED footprint: search_cases(litigants="Enforcement Directorate"), plus phrase-mode runs for each spelling. Rulings verified by CNR in the index and against the Supreme Court judgments. No figure in this post is estimated.
Verification links
- PMLA full-text search: https://ecourtsindia.com/search?q=PMLA
- Supreme Court PMLA docket: cc=SCIN01
- Bombay HC PMLA docket: cc=HCBM01
- Delhi HC PMLA docket: cc=DLHC01
- Madras HC PMLA docket: cc=HCMA01
- Karnataka HC PMLA docket: cc=KAHC01
- ED as litigant: litigant/enforcement-directorate and litigant/directorate-of-enforcement
- PMLA Section 45 text: IndiaCode
Vijay Madanlal Choudhary set the frame in 2022. The rulings since then decide who actually gets out. Both are now in the record, and both can be read case by case.
Further reading: The Election Petition Graveyard, Cheque Bounce in India: Inside the Section 138 Litigation Crisis, The NCLT Scorecard.
Frequently Asked Questions
What are the twin conditions for bail under Section 45 of the PMLA?
Section 45 bars bail for a money laundering accused unless the Public Prosecutor has had a chance to oppose it and, if opposed, the court is satisfied there are reasonable grounds to believe the accused is not guilty and is unlikely to offend while on bail. The burden shifts to the accused. Read the section on IndiaCode.
Is bail still the rule under PMLA after Vijay Madanlal Choudhary?
Yes, in a qualified way. In Prem Prakash v. Union of India (28 August 2024) the Supreme Court held that bail is the rule and jail the exception applies to PMLA too. Section 45 restricts bail but is not an absolute bar, and the court’s discretion remains judicial. The case record is at SCIN010156082024.
Can long custody without trial get a PMLA accused bail?
Yes. In Manish Sisodia (9 August 2024) and V. Senthil Balaji (26 September 2024), the Supreme Court granted bail because custody was long and the trial was unlikely to end soon. It read the Article 21 right to a speedy trial into Section 45. You can open both case records through eCourtsIndia search.
What did Pankaj Bansal decide about ED arrests?
In Pankaj Bansal v. Union of India, decided on 3 October 2023, the Supreme Court held that the Enforcement Directorate must give an arrested person the grounds of arrest in writing, as a matter of course. Reading them out is not enough. The rule applies to arrests after that date. The arrest power itself is in PMLA Section 19.
How many PMLA cases are indexed on eCourtsIndia?
On 23 September 2026 the eCourtsIndia index returned 12,003 records mentioning the PMLA. Of these, 2,092 also mention Section 45, 10,227 are disposed and 1,025 are pending. The Supreme Court holds 902. Counts change as courts upload orders, so re-run the PMLA search for the current figure.
How many court cases name the Enforcement Directorate?
About 27,000. A litigant search for Enforcement Directorate returns 26,955 records across both common spellings. The Lucknow district court holds 6,916, mostly property-attachment applications from 2024 and 2025, followed by the Supreme Court and the Delhi High Court. For related agencies, see our guide to anti-corruption court cases.