The Delhi High Court has granted regular bail to Wahidur Rahman, an accused in a money laundering case arising from investigations into the Popular Front of India (PFI) and the Social Democratic Party of India (SDPI). The court observed that the amount allegedly linked to the accused was relatively small compared to the overall allegations in the case and noted that the trial is likely to take a long time to conclude.
Case Background
The Enforcement Directorate (ED) registered the money laundering case on the basis of an NIA FIR alleging that office-bearers and members of PFI were involved in raising funds for activities linked to offences under the Unlawful Activities (Prevention) Act (UAPA).
According to the ED, SDPI functioned as a front organisation for PFI and was used to channel and conceal funds. The agency alleged that Wahidur Rahman, who was stated to have worked as a Physical Education trainer with PFI, helped route money through various bank accounts before it reached SDPI.
The ED claimed that transactions worth ₹3.15 lakh were linked to the petitioner and alleged that these transfers were part of a layering process intended to disguise the source of funds.
Arguments Before the Court
The petitioner argued that he was named for the first time only in the seventh supplementary prosecution complaint filed in 2025, despite the investigation having started much earlier.
His counsel contended that the ED had failed to establish how the money involved constituted “proceeds of crime” generated from any scheduled offence. It was also argued that the total amount attributed to him was only ₹3.15 lakh, far below the ₹1 crore threshold referred to in the proviso to Section 45 of the Prevention of Money Laundering Act (PMLA).
The ED opposed bail, arguing that the petitioner had close links with PFI and SDPI and had actively participated in transactions that allegedly helped conceal the source of funds. The agency relied on bank records, statements and other material collected during the investigation.
Court’s Observations
Justice Anup Jairam Bhambhani observed that the existence of an email address containing the acronym “PFI” or contacts saved in a phone under names such as “PFI” or “SDPI” could not, by themselves, justify denial of bail.
The court also noted that the petitioner’s name surfaced only in the seventh supplementary complaint and not during earlier stages of the investigation.
Referring to the financial allegations, the bench observed that while the ED alleged that SDPI accounts had received more than ₹32 crore over the years, only ₹3.15 lakh was linked to the petitioner.
“The proportion of Rs. 3.15 lacs vis-à-vis Rs. 32.94 crores is so minuscule,” the court observed while assessing the petitioner’s alleged role.
The court further noted that the ED had not prima facie demonstrated how the funds in question were derived from a specific scheduled offence, a requirement for invoking money laundering provisions under the PMLA.
Decision
Taking into account the petitioner’s alleged role, the limited amount attributed to him, the delay in arraigning him as an accused, the reasoning adopted in a co-accused’s bail order, and his incarceration for more than one year while the case remained at the stage of arguments on charge, the Delhi High Court held that continued detention was not warranted.
The court granted regular bail to Wahidur Rahman, subject to conditions including furnishing a personal bond of ₹50,000 with one surety, surrendering his passport if held, refraining from contacting witnesses, and cooperating with the proceedings. The bail application was accordingly allowed.
Case Details:
Case Title: Wahidur Rahman v. Directorate of Enforcement
Case Number: BAIL APPLN. 3796/2025
Judge: Justice Anup Jairam Bhambhani
Decision Date: May 29, 2026
