As per case facts, the Petitioner, Ashish Bhalla, challenged his arrest by the Directorate of Enforcement (ED) and subsequent remand orders. He argued that the initial FIR, the basis of ... the ECIR, was quashed by the Delhi High Court and that his arrest violated PMLA Section 19, with non-cooperation being an invalid arrest ground. The question arose whether the Petitioner's arrest and consequential proceedings were lawful, especially regarding the predicate offense's validity and PMLA compliance. Finally, the High Court dismissed the Writ Petition, stating that the FIR was quashed only on technicalities for the Petitioner, not on merits, and other predicate FIRs persisted. The Court confirmed that PMLA Section 19 requirements, including conveying grounds of arrest and reasons to believe, were duly met, and non-cooperation was not the sole basis for arrest. Judicial review at this stage does not involve a merits review.