Fugitive diamond merchant Nirav Modi is facing severe constraints inside a London prison that are hampering his ability to prepare for an upcoming civil trial, the High Court in London was informed on Friday.

The 54-year-old accused wanted in India to face fraud and money laundering charges linked to the estimated $2 billion Punjab National Bank loan scam, is currently lodged in a small shared cell in HMP Pentonville without access to most of his legal paperwork.

He was moved from HMP Thameside in south London to HMP Pentonville in October to facilitate an appearance in an unrelated debt case.

At a pre trial review hearing for an unpaid Bank of India loan worth $8 million, Judge Simon Tinkler was told that Modi sought more time to prepare his defence and witness statement ahead of the trial scheduled for January 2026.

“It seems to me that Mr Modi would benefit from having access to his previous handwritten notes,” said Justice Tinkler.

“It seems to me that we are very close to the point at which the absence of papers for Mr Modi would mean that he is not in a position to prepare for the trial in a way that means he can fairly present his case. This is, in particular, in relation to the disclosure documents, including his annotations, which, on his own evidence, took some six weeks or eight weeks to compile,” he said.

The move between the two Category B prisons for relatively low risk convicts was described during the online hearing as a "logistic convenience".

Justice Tinkler adjourned the adjournment application until a review hearing on 19 December and ordered HMP Thameside to transfer all legal paperwork from Modi’s former cell to his current one.

Barrister James Kinman, appearing for Modi, argued that his client would be at a substantial disadvantage without a delay to the 2026 trial, citing the cramped cell conditions, lack of IT facilities and limited workspace.

Representing Bank of India, barrister Tom Beasley opposed any further adjournment and pointed to what he described as several delaying tactics by Modi as well as his pending extradition to India.

“There is an opportunity to go ahead with the trial now before he is held in custody in India,” said Beasley.

Kinman also told the court that a hearing to reopen Modi’s unrelated extradition case is scheduled for later this month.

He submitted that there was a real possibility that Modi would either not be extradited or not before very late in 2026.

Modi, dressed in a grey T shirt, attended the proceedings via video link from HMP Pentonville and briefly confirmed the lack of access to his legal documents.

Bank of India, represented by RWK Goodman, is pursuing Modi’s personal guarantee related to a loan to Dubai incorporated Firestar Diamond FZE.

Modi has been behind bars in London since his arrest in March 2019 in connection with the extradition proceedings. His multiple bail applications have been rejected on the grounds that he poses a flight risk, most recently in May this year.

There are three criminal cases pending against him in India. The Central Bureau of Investigation is probing the PNB fraud, the Enforcement Directorate is pursuing a money laundering case linked to the alleged fraud proceeds, and a third case relates to alleged interference with evidence and witnesses.

In April 2021, then UK home secretary Priti Patel ordered his extradition after courts established a prima facie case.

Modi exhausted his legal challenges to that order until recently, when his application to reopen his appeal was accepted in the UK and listed for a hearing later this month.