High Court of Karnataka Dismisses Successive Bail Petition in PMLA Case Due to Lack of Change in Circumstances. Third bail petition rejected as petitioner failed to demonstrate any material change in circumstances after earlier dismissals by High Court and Supreme Court.

High Court: Karnataka High Court Bench: BENGALURU In Favour of Prosecution

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2026-05-18 20:01:03

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Case Note & Summary

The petitioner, Mr. K. Ramakrishna, filed a successive bail petition under Section 439 of the Code of Criminal Procedure, 1973 (CrPC) (filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023) seeking enlargement on bail in Special C.C. No. 780/2022 (ECIR/BGZO/9/2020) for alleged offences punishable under Sections 3, 70, 4 and 8(5) of the Prevention of Money Laundering Act, 2002 (PMLA). The case was pending before the Principal City Civil and Sessions Judge, Bengaluru, registered by the respondent/Enforcement Directorate. The High Court noted that this was the third bail petition before it; earlier petitions had been dismissed by the High Court and the Supreme Court. The petitioner then approached the Trial Court again on different grounds invoking Section 479(1) of BNSS. The High Court, after hearing the matter, dismissed the petition, holding that successive bail petitions cannot be entertained without a change in circumstances.

Headnote

A) Criminal Procedure - Successive Bail Petition - Change in Circumstances - Section 439 CrPC, Section 483 BNNS - The petitioner filed a third successive bail petition without demonstrating any material change in circumstances after earlier petitions were dismissed by the High Court and the Supreme Court - Held that successive bail petitions cannot be entertained on the same grounds without change in circumstances (Paras 1-2).

Issue of Consideration

Whether the petitioner is entitled to bail in a successive bail petition under PMLA when there is no change in circumstances.

Final Decision

The High Court dismissed the criminal petition, rejecting the bail prayer.

Law Points

Successive bail petition
Change in circumstances
Section 439 CrPC
Section 483 BNSS
PMLA twin conditions
Section 45 PMLA

Case Details

2024 LawText (KAR) (11) 16

Criminal Petition No. 9930/2024

2024-11-23

H.P. Sandesh

Sri Balakrishna M.R. (for petitioner), Sri Unnikrishnan M. (for respondent)

Mr. K. Ramakrishna

The Assistant Director, Directorate of Enforcement, Bengaluru Zonal Office

Nature of Litigation

Criminal bail petition under PMLA

Remedy Sought

Enlargement on bail in Special C.C. No. 780/2022

Filing Reason

Petitioner sought bail for alleged offences under PMLA

Previous Decisions

Earlier bail petitions dismissed by High Court and Supreme Court; Trial Court also rejected subsequent petition

Issues

Whether successive bail petition is maintainable without change in circumstances

Submissions/Arguments

Petitioner argued on different grounds invoking Section 479(1) BNSS Respondent opposed bail

Ratio Decidendi

Successive bail petitions cannot be entertained without a material change in circumstances; the petitioner failed to demonstrate any such change.

Judgment Excerpts

This successive bail petition is the third petition before this Court and this Court heard and dismissed the earlier petition and the same was challenged before the Apex Court and the Apex Court also dismissed the same and the petitioner again approached this Court and the same was rejected.

Procedural History

The petitioner filed successive bail petitions; first two were dismissed by the High Court and the Supreme Court; thereafter, the petitioner approached the Trial Court again under Section 479(1) BNSS; the present petition is the third before the High Court.