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In its 16 March 2021 decision in Babulal Verma v Enforcement Directorate (Criminal Application 201/2021 with Criminal Bail Application 974/2021), the Bombay High Court was posed with an issue regarding the fate of proceedings under the Prevention of Money Laundering Act (PMLA) 2002 in the event of compromise or compounding in a predicate offence. Facts The proceedings were brought before the Bombay High Court by means of a petition under Section 482 of the Code of Criminal Procedure 1973. Significantly, the applicants sought to set aside an order of a special judge which had allowed the application of Respondent 1, the Enforcement Directorate, for an extension of the applicants judicial custody period and rejected the application preferred by the applicants (which sought a grant of bail). The applicants, based on the compromise that ensued in the proceedings relating to a predicate offence, challenged the order of the special judge, among other things, on the ground that:

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