On 27 August 2024 the Supreme Court granted bail to K. Kavitha in the Delhi excise-policy money-laundering case, holding that the first proviso to Section 45(1) PMLA — which relaxes the twin bail conditions for a woman — cannot be denied merely because the woman is highly educated, sophisticated, or a Member of Parliament or Legislative Assembly. The Court found the Delhi High Court had misread Saumya Chaurasia to confine the proviso to 'vulnerable women'. A digest of the pro-applicant pole of the s.45 proviso debate, the excise-policy context, and how it pairs against the restrictive discretionary reading.
On 14 December 2023 the Supreme Court refused PMLA bail to Saumya Chaurasia, holding that the words 'may be' in the first proviso to Section 45(1) make the relaxed-bail benefit for a woman discretionary — to be extended only after weighing the extent of her involvement and the nature of the evidence — and cautioning counsel against inaccurate representations in special leave petitions.