The Enforcement Directorate (Kolkata Zonal Office-I) filed an application under Section 439(2) CrPC (corresponding to Section 483 BNSS, 2023) before the Calcutta High Court seeking cancellation of regular bail granted to Jitendra Prasad Verma by the City Sessions Court (Special PMLA Court) on 14 November 2025. Verma was accused of money laundering under Sections 3 and 4 of the PMLA in connection with the Sahara Group collapse, with investigators recovering cash ledgers documenting illicit transactions of ₹214.66 Crores, parallel cash movements of ₹76.29 Crores across 28 cities, and a personal commission of ₹5.75 Crores from his premises. The High Court found the Special Court's bail order to be perverse and legally unsustainable, holding that it had ignored the mandatory twin conditions under Section 45(1) of the PMLA, wrongly relied on the absence of oral witness testimony while disregarding overwhelming documentary evidence, and erroneously treated the PMLA offense as dependent on the status of the predicate offense. The Division Bench emphasised that a PMLA investigation is independent of the predicate offense proceedings, that the burden of proof is inverted under Section 24 of the PMLA, and that individual liberty under Article 21 cannot be considered in isolation from the collective financial harm to thousands of defrauded depositors.