The Punjab and Haryana High Court has dismissed a regular bail petition filed by Sanjeev Arora in an alleged money laundering case involving mobile phone exports worth approximately ₹102.50 crore. Justice Kuldeep Tiwari passed the order on October 16, 2026, holding that Arora had failed to satisfy the statutory conditions required for bail under the Prevention of Money Laundering Act, 2002 (PMLA).
The Court examined the investigation records, financial transactions, supplier networks and electronic evidence concerning exports allegedly made by Hampton Sky Realty Limited (HSRL) to two UAE-based entities.
Background
The Enforcement Directorate (ED) arrested Arora on May 9, 2026. The proceedings arose from FIR No. 137 dated April 18, 2026, registered at Udyog Vihar Police Station, Gurugram, and the subsequent registration of ECIR No. HIU-I/14/2026.
According to the prosecution, HSRL, which had primarily operated in real estate, entered the mobile phone export business in 2023 and reported exports worth ₹102.50 crore during the 2023–24 financial year. The ED alleged that the transactions involved fictitious purchase invoices, shell suppliers and circular movement of funds.
The agency also relied on mobile phone identification number (IMEI) records, which allegedly showed that certain handsets declared as exports had already been sold or activated in India. It further alleged that the transactions facilitated wrongful claims of IGST refunds and export incentives.
Arora disputed these allegations, arguing that the exports were genuine, the shipments had undergone customs clearance and the evidence did not justify his continued detention. He also raised objections to the legality of his arrest and cited his medical condition and the expected length of the trial.
Justice Tiwari held that the stringent twin conditions under Section 45 of the PMLA apply even when a bail petition is considered by a constitutional court. The applicant must satisfy the Court that there are reasonable grounds to believe that he is not guilty of the alleged offence and is unlikely to commit an offence while on bail.
The Court observed:
“The instant petition for regular bail must, therefore, be adjudicated considering the rigours of Section 45 of the PMLA, 2002, which create a statutory embargo on the grant of bail for offences under the Act.”
The Court considered the ED’s findings concerning the supplier network, financial trail and alleged discrepancies in export records. It found that the material, viewed cumulatively at the bail stage, did not provide reasonable grounds to believe that Arora was not guilty of the alleged offence.
On the customs clearance argument, the Court observed that the issuance of a Let Export Order could not, by itself, establish that the transactions were genuine or justify bail when other investigative material raised concerns about the underlying movement of goods.
Arora also sought bail on medical grounds, citing pulmonary thromboembolism, cardiac and kidney-related issues, diabetes and hypertension. After examining the medical records, the Court noted that his condition was stable following treatment and that the material did not indicate an urgent need for further medical intervention. It therefore found no sufficient ground for granting bail under the medical exception in Section 45(1) of the PMLA.
The Court ultimately held:
“In summa, finding no merit in the submissions advanced on behalf of the petitioner, the instant petition seeking regular bail is dismissed.”
The Court clarified that its observations were limited to deciding the bail petition and would not influence the ongoing trial, which the Special Court must decide independently.
Case Details
Case Title: Sanjeev Arora v. Directorate of Enforcement and Another
Case Number: CRM-M-34651-2026 (O&M)
Judge: Justice Kuldeep Tiwari
Decision Date: October 16, 2026
