The Delhi High Court has granted regular bail to Wahidur Rahman Jainullabudeen alias J. Wahid in a money laundering case linked to the banned Popular Front of India (PFI) and the Social Democratic Party of India (SDPI).
Justice Anup Jairam Bhambhani held that the petitioner’s alleged involvement was limited to transactions worth ₹3.15 lakh.
The Court noted that this amount was insignificant compared to the ₹32.94 crore allegedly received in SDPI bank accounts.
Even while applying the stringent conditions under Section 45 of the Prevention of Money Laundering Act, 2002 (PMLA), the Court found no justification for continued detention.
ED’s Allegations
The Enforcement Directorate (ED) alleged that the petitioner deposited money into the bank accounts of certain individuals.
According to the agency, those individuals later transferred the funds to SDPI accounts.
The ED relied on bank records and statements recorded under Section 50 of the PMLA.
The agency claimed that the petitioner routed money through third parties and directly transferred funds to SDPI accounts.
It further alleged that these transactions formed part of efforts to channel funds linked to PFI and SDPI activities.
The ED also highlighted that the petitioner claimed an annual income of only ₹1 lakh despite carrying out significantly larger financial transactions.
Court Rejects Reliance on Contact Details
The High Court examined the material relied upon by the ED.
The Court observed that email addresses containing the acronym “PFI” and phone contacts saved as “PFI” or “SDPI” could not, by themselves, amount to incriminating evidence.
Justice Bhambhani noted that people associated with an organisation often maintain such contact details for professional or functional reasons.
The Court held that these circumstances, without supporting evidence, could not justify denial of bail.
Delay in Naming the Petitioner
The Court also considered the timeline of the investigation.
The ECIR was registered in September 2022 and originated from an FIR lodged in April 2022.
However, investigators named the petitioner as an accused only in the seventh supplementary prosecution complaint filed in May 2025.
The Court observed that if the petitioner had played a central role in the alleged activities of PFI or SDPI, the investigation would likely have identified his involvement much earlier.
Limited Financial Link Weighed in Favour of Bail
A major factor in the Court’s decision was the limited financial connection attributed to the petitioner.
The Court noted that SDPI accounts allegedly received ₹32.94 crore between 2010 and 2025.
Out of that amount, investigators linked only ₹3.15 lakh to the petitioner.
Even if the allegations were accepted at this stage, the Court held that such a small proportion did not justify treating the petitioner as a significant participant in the alleged money laundering operation.
Section 45 PMLA Conditions Considered
Justice Bhambhani referred to the proviso to Section 45 of the PMLA.
The Court noted that the provision contemplates a monetary threshold of ₹1 crore.
Since the amount attributed to the petitioner was only ₹3.15 lakh, the Court held that the rigours of the twin conditions under Section 45 were less severe in the present case.
The Bench therefore adopted a more liberal approach while considering bail.
No Prima Facie Proof of Proceeds of Crime
The Court also referred to an earlier bail order granted to a co-accused.
In that case, a coordinate Bench found no material showing that the accused had dealt with “proceeds of crime” as defined under the PMLA.
Applying similar reasoning, Justice Bhambhani held that the ED had not prima facie demonstrated that the funds allegedly transferred by the petitioner originated from any identified scheduled offence.
The Court noted that establishing such a link is a foundational requirement for a money laundering charge.
Long Trial and Continued Custody
The High Court also considered the length of custody and the likely duration of the trial.
The petitioner has remained in custody since March 20, 2025.
The case is still at the stage of arguments on charge.
The prosecution proposes to examine around 250 witnesses and rely on more than 600 documents spread across multiple complaints.
Given the scale of the proceedings, the Court observed that the trial would take considerable time.
The Bench held that prolonged incarceration of an undertrial would not be consistent with principles of personal liberty.
Bail Conditions
Allowing the application, the Court directed the petitioner to furnish a personal bond of ₹50,000 along with one surety from a family member.
The Court also directed him to surrender his passport.
Additionally, it prohibited him from contacting witnesses and imposed other standard conditions to ensure a fair trial.
Case Details
Case Title: Wahidur Rahman Jainullabudeen @ Wahidur Rahman @ J. Wahid v. Directorate of Enforcement
Court: Delhi High Court
Judge: Justice Anup Jairam Bhambhani
Decision Date: May 29, 2026
