FININ2MIN · JUDGMENT INTELLIGENCE
Securities · F2J-C-2984

Central Bureau of Investigation v. Sanjay Pandey; connected Chitra Ramakrishna petition

A connected PMLA bail assessment may be considered in a CBI bail case sharing the factual foundation if the court still assesses the CBI record and each accused’s role; the earlier order is not conclusive.

By CA Nikhil Gupta · Reviewed against the retained judgment 2026-09-26

Finin2min two-minute summary

A connected PMLA bail assessment may be considered in a CBI bail case sharing the factual foundation if the court still assesses the CBI record and each accused’s role; the earlier order is not conclusive. CBI challenges dismissed; distinct bail orders left standing

Court
Delhi High Court
Case
CRL.M.C. No. 2749/2023
Date
2026-09-23
Bench
Madhu Jain
Result
CBI challenges dismissed; distinct bail orders left standing
Neutral citation
Not stated in retained copy
CNR
DLHC010140592023
Connected matters
CRL.M.C. 2751/2023
Relevant period
See facts and judgment
Read complete judgment PDFPublic court copyOfficial court portal

What happened

CBI challenged December 2022 bail orders in its NSE telephone-monitoring case involving iSEC Services and allegations of roughly ₹4.54 crore paid under cyber-vulnerability work orders. The Special Judge had considered a connected High Court PMLA bail decision concerning Sanjay Pandey. CBI contended that its separate prosecution and Chitra Ramakrishna’s different role required independent analysis; a charge sheet was filed the day after the challenged bail orders.

Questions before the court

What each side argued

CBI argued that it was not a party to the ED bail proceeding and that the trial court imported prima facie conclusions. The respondents pointed to the shared FIR, recorded objections and individual role analysis. No post-release breach was alleged.

Why the court ruled this way

The High Court distinguished review of an original bail grant for perversity from cancellation based on later conduct. A related ED order could be relevant to the common facts and alleged predicate offences, though never binding on CBI or a substitute for independent judgment. The Special Judge had recorded CBI’s objections, identified Pandey’s circumstances and separately addressed the allegations against Ramakrishna. The charge sheet filed a day later could not retrospectively make the earlier bail assessment perverse.

Controlling point

A connected PMLA bail assessment may be considered in a CBI bail case sharing the factual foundation if the court still assesses the CBI record and each accused’s role; the earlier order is not conclusive.

Order and next steps

Both CBI petitions, CRL.M.C. 2749/2023 and 2751/2023, were dismissed. The 2022 CBI bail grants remained effective. The trial court was directed to proceed without being influenced by prima facie observations in these bail rulings.

Practical implications

When reviewing parallel agency proceedings, track which order concerns which person, offence and bail standard. A later charge sheet may require action at the proper procedural stage, but an original bail-order challenge focuses on the material available when discretion was exercised.

Limits of this ruling

Law and judgment source

The linked PDF is a complete public court-copy document. The official court portal is provided for independent verification; a stable judgment-specific official link was not independently established.

Source checked: 2026-09-26 · Judgment paragraphs: Paragraphs 43–80 · Later case history: not verified. Verify subsequent orders before reliance.

This page is informational. Verify the current official court record, subsequent history and applicable law, and obtain professional advice for a specific matter.