The Supreme Court upheld a High Court ruling rejecting an accused's plea for default bail in a CBI case involving large-scale cyber fraud. The Court affirmed that strict bail conditions under special statutes like the Prevention of Money Laundering Act apply, and that the twin conditions for bail must be satisfied even when investigating agencies miss statutory deadlines. The ruling clarifies that default bail rights are not automatic when PMLA or allied special laws govern the offence.

Default bail, also called statutory bail, arises under Section 167(2) CrPC (now Section 187 BNSS) when an investigating agency fails to file a chargesheet within the prescribed period: 60 days for most offences, 90 days for offences punishable with death, life imprisonment, or imprisonment of not less than 10 years. The accused's right to default bail is an indefeasible right that accrues the moment the deadline passes without a chargesheet being filed — unless the special law overrides it.

The complication in PMLA cases is that Section 167(2) CrPC must be read alongside Section 45 PMLA, which imposes the 'twin conditions' for bail: (1) the public prosecutor must be given an opportunity to oppose bail, and (2) the court must be satisfied that there are reasonable grounds to believe the accused is not guilty and is unlikely to commit any offence while on bail. The Supreme Court has consistently held in cases like Vijay Madanlal Choudhary v. Union of India (2022) that these twin conditions survive even in default bail scenarios under PMLA.

This ruling reinforces that default bail under PMLA is not purely mechanical. The accused cannot simply point to the calendar and walk free — the twin conditions act as a filtering layer. The examiner will test whether aspirants can distinguish the general CrPC default bail rule from the PMLA-modified version, and identify which section triggers which right.