David Uaine has been detained for the past two weeks facing forgery charges.
He was arrested following a lengthy police investigation over claims of Samoan passports being sold online in South Africa.
The Samoan Observer said his lawyer made an application for bail and assured the court he would not leave Samoa while further charges were pending.
The court ordered Mr Uaine to surrender his own travel documents, stay with his family and check in with his local police station twice a week.
Photo: RNZI/ Sally Round A view of Apia taken from outside police headquarters