"He moved here to raise capital, to explore where in the world he needed to be immigration wise. If he is given bail, he is willing to be tagged through an electronic device, have a phone that can be tracked," Montgomery said.
"Since he has an extradition case starting, there is no way he will run away. His daughter and son will be moving here, they are starting university," she added
Modi's bail plea has been rejected thrice already in London's Westminster Magistrates' Court.
Modi was arrested by Scotland Yard in connection with the PNB loan default case on March 19 this year.
India is seeking the diamond merchant's extradition to make him face the law of the land for allegedly committing economic offences like fraud and money laundering.
He has been lodged at Wandsworth prison in south-west London.