Issues: Whether the petitioner-company's agent/authorized signatory could be permitted to appear pursuant to summons issued for investigation under the Prevention of Money Laundering Act, 2002.

Analysis: The summons contemplated attendance by a Director or Authorized Signatory on behalf of the company. The company gave an undertaking through its Director that all directors would cooperate with the investigation and would personally appear whenever required. The investigating authority expressed no objection to accepting that undertaking and recording the statement of the authorized agent.

Conclusion: The authorized agent/signatory may appear in compliance with the summons, while the company and its directors must cooperate with the investigation and appear whenever required.

Issues: Whether the Adjudicating Authority's order concerning attachment of the petitioner's bank account could stand without consideration of the petitioner's detailed objections.

Analysis: The petitioner's detailed objections to the proposed attachment were not addressed in the impugned order, although objections of other persons were considered. The respondents accepted that the petitioner's objections required consideration and an appropriate order.

Conclusion: The matter is remitted to the Adjudicating Authority for consideration of the petitioner's objections and for passing necessary orders; all other contentions remain open.

Issues: (i) Whether the petitioner acquired an indefeasible right to default bail because the supplementary complaint, though filed within the prescribed period, was returned for compliance; (ii) Whether the petitioner satisfied the conditions for regular bail under the Prevention of Money Laundering Act.

Issue (i): Whether the petitioner acquired an indefeasible right to default bail because the supplementary complaint, though filed within the prescribed period, was returned for compliance.

Analysis: The supplementary complaint had been filed within the prescribed period. Its subsequent return for compliance did not, in the circumstances, create an indefeasible right to bail. The precedent concerning incomplete charge-sheets filed to defeat default bail was factually distinguishable.

Conclusion: The petitioner was not entitled to default bail. This finding is against the petitioner.

Issue (ii): Whether the petitioner satisfied the conditions for regular bail under the Prevention of Money Laundering Act.

Analysis: The material prima facie indicated the petitioner's involvement in activities connected with proceeds of crime, including alleged interference with the investigation and auction of attached properties. The Court was not satisfied that there were reasonable grounds to believe that the petitioner was not guilty or that he would not commit an offence while on bail, as required by the twin conditions.

Conclusion: The petitioner did not satisfy the statutory conditions for grant of bail. This finding is against the petitioner.

Final Conclusion: Bail was unavailable because neither default-bail entitlement nor the statutory threshold for release in a money-laundering offence was established.

Ratio Decidendi: Filing of a supplementary complaint within the prescribed period is not rendered ineffective for default-bail purposes merely because it is returned for procedural compliance, and bail under the money-laundering regime requires satisfaction of the statutory twin conditions.

Issues: Whether the petitioner was entitled to anticipatory bail in a money-laundering investigation, including on medical grounds.

Analysis: The material at the investigation stage indicated that the petitioner allegedly facilitated the award of a sub-contract to an entity connected with his son and that the alleged proceeds were transferred to family members. The absence of a direct credit to the petitioner's account was not determinative. The allegations, financial material and need to trace the money trail required further investigation; at the pre-arrest bail stage, the evidence was not to be assessed conclusively. The statutory twin conditions for bail were not capable of being satisfied in the petitioner's favour at that stage. The available medical record did not establish a continuing serious condition, medical emergency, or urgent intervention warranting protection from arrest.

Conclusion: The petitioner was not entitled to anticipatory bail, either on merits or medical grounds.

Issues: (i) Whether Section 362 of the Code of Criminal Procedure, 1973 bars the High Court from modifying a condition imposed in its earlier bail order; (ii) Whether the condition requiring deposit of Rs. 64,00,000 in fixed deposit as a prerequisite to bail warranted revocation.

Issue (i): Whether Section 362 of the Code of Criminal Procedure, 1973 bars the High Court from modifying a condition imposed in its earlier bail order.

Analysis: Section 362 applies only to a judgment or final order disposing of a case. A bail order is interlocutory in nature and does not finally determine the criminal case; bail conditions may be varied where changed circumstances justify such variation. The inherent jurisdiction preserved by Section 482, read with the High Court's status as a constitutional court of record under Article 215, may be exercised to prevent injustice and secure the ends of justice. The contrary coordinate-bench view was treated as per incuriam because it did not consider the statutory meaning of judgment and the binding authorities treating bail orders as interlocutory.

Conclusion: Section 362 does not bar modification or revocation of a condition imposed in a bail order; the High Court may exercise inherent jurisdiction under Section 482 where the circumstances warrant it.

Issue (ii): Whether the condition requiring deposit of Rs. 64,00,000 in fixed deposit as a prerequisite to bail warranted revocation.

Analysis: A bail condition requiring deposit of money without prima facie determination of guilt is unreasonably onerous and cannot convert criminal proceedings into a mechanism for recovery of alleged dues. The prosecution sanction against co-accused had been quashed, the trial proceedings had been closed and records consigned, and there was no prospect of an early conclusion of trial. The continuing restraint on the petitioner's funds, deposited only until conclusion of trial, caused failure of justice in the materially changed circumstances.

Conclusion: The deposit condition was revoked, and the fixed-deposit amount with accrued interest was directed to be released to the petitioner.

Final Conclusion: The inherent jurisdiction was invoked to remove an unjustified continuing bail condition in light of the stalled criminal proceedings and the unreasonable financial restraint.

Ratio Decidendi: A bail order is interlocutory and is not protected from variation by the bar under Section 362; the High Court may, under its inherent jurisdiction, modify or revoke an onerous bail condition when changed circumstances make its continuance unjust.

Issues: (i) Whether the payments credited to the applicants for physical-education training prima facie constituted proceeds of crime so as to attract the offence of money-laundering and the bail rigours under the Prevention of Money Laundering Act, 2002; (ii) Whether post-arrest statements recorded under Section 50 could support the prosecution case; (iii) Whether parity, prolonged incarceration, delayed trial and the triple test justified regular bail.

Issue (i): Whether the payments credited to the applicants for physical-education training prima facie constituted proceeds of crime so as to attract the offence of money-laundering and the bail rigours under the Prevention of Money Laundering Act, 2002.

Analysis: Property can qualify as proceeds of crime only where it is derived or obtained as a result of an already accomplished scheduled offence. The payments relied upon were stated to be remuneration for training services, substantially received before the association was declared unlawful and before the predicate FIR. Neither applicant was charge-sheeted in the predicate offence, and no material prima facie established that the credited sums were derived from an identified and accomplished scheduled offence. Personal receipt of money may raise a question of dominion or control only after the money is first shown to be proceeds of crime; it cannot itself establish that foundational requirement. The amounts attributed to the applicants were also below the monetary threshold referred to in the proviso to Section 45.

Conclusion: The alleged payments were not prima facie shown to be proceeds of crime, and the applicants satisfied the applicable bail threshold under Section 45, in favour of the applicants.

Issue (ii): Whether post-arrest statements recorded under Section 50 could support the prosecution case.

Analysis: Statements recorded by the investigating agency after the applicants' formal arrest were prima facie affected by the protection against compelled self-incrimination and the bar relating to confessional statements. The remaining pre-arrest statements describing payments as honorarium established only receipt of money, not that the money was derived from a scheduled offence.

Conclusion: The post-arrest statements could not prima facie be relied upon against the applicants, and the pre-arrest statements did not establish proceeds of crime, in favour of the applicants.

Issue (iii): Whether parity, prolonged incarceration, delayed trial and the triple test justified regular bail.

Analysis: The applicants had remained in custody for over two years and three months; charges were yet to be framed against them, and the extensive prosecution material and large number of witnesses made an early trial unlikely. Continued pre-trial detention in those circumstances would offend personal liberty. Their role was not prima facie graver than that of co-accused already granted bail. They were not shown to be flight risks, the principal evidence was seized documentary and digital material, and no substantial risk of witness influence was established.

Conclusion: The applicants were entitled to regular bail on grounds of parity, prolonged incarceration, likely delay in trial and satisfaction of the triple test, in favour of the applicants.

Final Conclusion: The applicants obtained release on regular bail, while the merits of the pending trial remain open for independent determination.

Ratio Decidendi: For a money-laundering prosecution, dominion or control over funds is legally relevant only after the funds are prima facie shown to be derived from an accomplished scheduled offence; prolonged pre-trial incarceration and an unlikely early trial can independently justify bail despite statutory restrictions.

Issues: Whether the petitioner made out an exceptional and bona fide medical exigency warranting permission to travel abroad despite the conditions of bail and the prosecution's apprehension of flight risk.

Analysis: The right to travel abroad is an aspect of personal liberty, but it is not absolute and must be weighed against the nature of the allegations, the conduct of the accused, and the risk of evading prosecution. The request was examined in the context of a serious money-laundering prosecution, the stage of trial, the petitioner's financial capacity and international links, and the absence of cogent medical material showing that the proposed foreign treatment was the only available line of treatment or that equivalent treatment was unavailable in India. The Court also noted that medical facilities in India are comparable to foreign facilities and that a preference for treatment abroad cannot override the requirement of securing the accused's presence for trial.

Conclusion: The petitioner failed to establish a bona fide exceptional medical case, and the refusal of permission to travel abroad was held to be justified.

Ratio Decidendi: Permission to travel abroad by an on bail may be refused where the claimed medical necessity is not substantiated by reliable medical material and the Court finds a real risk that foreign travel may impede the criminal process.

Issues: (i) Whether retention of the seized records, cash, jewellery and electronic devices was validly authorised under the Prevention of Money Laundering Act, 2002; (ii) Whether quashing of the ECIR precluded continuation of the retention proceedings when operation of the quashing judgment had been stayed by the Supreme Court; (iii) Whether the proceedings were barred by limitation.

Issue (i): Whether retention of the seized records, cash, jewellery and electronic devices was validly authorised under the Prevention of Money Laundering Act, 2002.

Analysis: An order under Section 17(4), read with Section 20(1), concerns retention for adjudication and requires material giving rise to recorded reasons to believe that the property is required for proceedings under Section 8. The material disclosed unexplained capital contributions and unsecured loans, financial links with entities under investigation, and an absence of satisfactory evidence regarding the source and flow of funds. The statutory requirements for retention were therefore met.

Conclusion: The retention order was validly made and was rightly affirmed.

Issue (ii): Whether quashing of the ECIR precluded continuation of the retention proceedings when operation of the quashing judgment had been stayed by the Supreme Court.

Analysis: Stay of the operation of the judgment quashing the ECIR rendered that judgment ineffective during the pendency of the Supreme Court proceedings. The position preceding the quashing consequently continued, and the ECIR could not be treated as remaining quashed for purposes of the retention proceedings.

Conclusion: Continuation of the retention proceedings was not invalidated by the quashing judgment.

Issue (iii): Whether the proceedings were barred by limitation.

Analysis: The Explanation to Section 8(3) excludes the period during which investigation remains stayed by a court when computing the 365-day period. Upon excluding the operative stay period, the prosecution complaint was filed within the prescribed period.

Conclusion: The proceedings were within limitation.

Final Conclusion: The statutory retention process and its appellate confirmation remained legally sustainable.

Ratio Decidendi: Where the statutory material establishes recorded reasons to believe that seized property may be involved in money laundering, retention may continue for adjudication; a stayed quashing order cannot defeat the underlying proceedings, and the period of judicial stay is excluded in computing the statutory limitation period.

Issues: Whether the applicant was entitled to bail in proceedings under the Prevention of Money Laundering Act, 2002, in view of the cancellation reports in the predicate Himachal Pradesh FIRs, the absence of any identified proceeds of crime attributable to the applicant, and the period of incarceration already undergone.

Analysis: The bail request turned on whether the foundational scheduled offences were established and whether any proceeds of crime had been identified so as to attract the offence under Section 3 of the Prevention of Money Laundering Act, 2002. The predicate FIRs from Himachal Pradesh had either resulted in accepted cancellation reports or cancellation reports had been filed, and no independent material was shown to establish a subsisting scheduled offence against the applicant from those FIRs. The Court also noted that the complaint did not identify any asset of the applicant as proceeds of crime, and that mere allegations of unexplained cash or illegality in mineral dealings, without linkage to a scheduled offence, were insufficient to sustain continued custody under the PMLA. The applicant had remained in custody for more than 18 months, the investigation was complete, and no material was shown to indicate flight risk, tampering with evidence, or intimidation of witnesses.

Conclusion: Bail was granted in favour of the applicant.

Ratio Decidendi: Where the predicate scheduled offence is not shown to subsist and no proceeds of crime are identified against the accused, continued detention under the Prevention of Money Laundering Act, 2002 is not justified and bail may be granted, particularly when custody is prolonged and trial is not likely to conclude expeditiously.

Issues: Whether a Special Court constituted under the Prevention of Money Laundering Act, 2002, acquires jurisdiction to try a scheduled offence on committal of that case under Section 44(1)(c), even if it is not the notified court to try the scheduled offence.

Analysis: Section 44(1)(a) provides that the offence of money-laundering and the connected scheduled offence are triable by the Special Court for the area where the offence is committed. Section 44(1)(c) specifically contemplates committal of the scheduled offence to the Special Court where cognizance has been taken by a different court, and mandates that the Special Court proceed from the stage at which the case is committed. Section 71 gives overriding effect to the Act over inconsistent laws. Reading these provisions together, the Special Court under the Act becomes competent to try the scheduled offence after committal.

Conclusion: The Special Court under the Prevention of Money Laundering Act, 2002, has jurisdiction to try the scheduled offence after committal under Section 44(1)(c), and the impugned order was sustained.

Issues: Whether the petitioner, after an earlier refusal of bail, established changed circumstances and continued delay in the proceedings sufficient to justify grant of regular bail in a prosecution under the Prevention of Money Laundering Act, 2002.

Analysis: The Court noted that successive bail applications are maintainable when fresh circumstances arise and that the earlier rejection does not bar reconsideration if subsequent developments materially alter the position. It examined the post-order changes, including grant of bail to the petitioner in the predicate offence, filing of the charge sheet there, filing of a supplementary complaint against other accused in the money-laundering case without their arrest, and the continued pre-cognizance stage with a voluminous record and numerous witnesses. The Court also relied on the constitutional primacy of Article 21 and the principle that prolonged incarceration without realistic prospects of early trial may outweigh the statutory rigour of bail restrictions under the PMLA.

Conclusion: The petitioner was held entitled to bail on the ground of changed circumstances and continued delay, and the plea for bail was allowed.

Final Conclusion: The proceedings were not finally advanced to trial in a manner that justified further incarceration, and conditional liberty was granted to the petitioner.

Ratio Decidendi: In a PMLA case, where subsequent material developments show genuine changed circumstances and the trial remains unlikely to conclude within a reasonable time, the constitutional protection of personal liberty under Article 21 can justify grant of bail notwithstanding the rigour of Section 45.

Issues: (i) Whether information shared by the Enforcement Directorate under Section 66(2) of the Prevention of Money-Laundering Act, 2002 could lawfully be acted upon for registration of crime under other laws; (ii) Whether the invocation of offences under the Unlawful Activities (Prevention) Act, 1967 disclosed sufficient prima facie material to prevent interdiction of investigation at the threshold.

Issue (i): Whether information shared by the Enforcement Directorate under Section 66(2) of the Prevention of Money-Laundering Act, 2002 could lawfully be acted upon for registration of crime under other laws.

Analysis: Section 66(2) expressly permits the Director or authorised authority, on forming an opinion that provisions of any other law have been contravened, to share the information with the concerned agency for necessary action. The provision is intended to ensure that material uncovered during investigation under one enactment is not confined to that statute when it discloses violations under other laws. The communication in question was detailed and disclosed alleged contraventions under FEMA and other penal statutes, so it could not be treated as lacking authority merely because the information originated from proceedings under PMLA.

Conclusion: The sharing of information and the consequential registration of crime were held to be legally sustainable.

Issue (ii): Whether the invocation of offences under the Unlawful Activities (Prevention) Act, 1967 disclosed sufficient prima facie material to prevent interdiction of investigation at the threshold.

Analysis: The allegations disclosed a network of foreign funding, withdrawal of funds through ATMs using debit cards, concealment of identity through false naming, circulation of cards, and alleged channelisation of funds into regions affected by left wing extremism. The Court held that at the stage of investigation it was not required to return findings of guilt, and that the material on record was not so barren as to justify judicial interference. The alleged conduct was considered sufficient to permit investigation into unlawful activity, raising of funds for a terrorist act, and conspiracy or preparation related thereto.

Conclusion: The invocation of UAPA and continuation of investigation were held to be justified at the prima facie stage.

Final Conclusion: The petitions were rejected, the criminal investigation was allowed to continue, and the Court declined to exercise inherent jurisdiction to halt the proceedings at the threshold.

Ratio Decidendi: Where statutory information-sharing power expressly authorises communication of contraventions of other laws, and the record discloses prima facie material suggesting serious offences touching national security, investigation should not be interdicted at its inception.

Issues: Whether the petitioner should be granted regular bail in the money-laundering proceedings.

Analysis: The nature and gravity of allegations indicated misuse of local area development funds through 32 tenders for sports equipment and diversion of public funds. The material from the investigation was considered insufficient to warrant release at that stage.

Conclusion: Regular bail was declined.

Issues: Whether the applicant was entitled to regular bail in a prosecution under the Prevention of Money Laundering Act, 2002 despite the pending predicate offence, and whether the statutory conditions for bail under Section 45 were satisfied.

Analysis: The application arose from allegations that the applicant, then District Collector, was involved in a land-use conversion racket in which illegal gratification was collected and layered as proceeds of crime. The Court held that proceedings under the Prevention of Money Laundering Act, 2002 are maintainable even when the predicate offence is still pending, so long as the scheduled offence is registered and the allegations disclose a nexus with proceeds of crime. Relying on the statutory scheme and binding precedent, the Court treated money laundering as an independent offence, the power of arrest under Section 19 as an investigative power exercised on reason to believe, and statements recorded under Section 50 as relevant at the bail stage. The Court further held that the bail enquiry under Section 45 is governed by the twin conditions, requiring reasonable grounds to believe that the accused is not guilty and will not commit an offence while on bail, and found that the material collected, including statements, digital evidence, and hisaab sheets, prima facie indicated the applicant's active role and receipt of a substantial share of the alleged illegal gratification. The Court also rejected parity, delay, and medical grounds as insufficient to displace the statutory rigour.

Conclusion: The applicant did not satisfy the twin conditions for bail and was held not entitled to release.

Issues: Whether the writ petition was entertainable despite the statutory remedy under the Prevention of Money-Laundering Act, 2002; whether the Authorized Officer had valid "reason to believe" on the basis of material in possession to issue the provisional attachment order; and whether property acquired before the scheduled offence could nevertheless be attached as equivalent value of proceeds of crime.

Analysis: The Court held that though an alternative remedy existed before the Adjudicating Authority and appellate forums under the Act, writ jurisdiction could still be exercised where the challenge went to the root of jurisdiction. On the materials referred to in the provisional attachment order, the Court found that the Authorized Officer had before him relevant investigation material, statements, seized documents, GST records and financial trail evidence sufficient to form the requisite belief that proceeds of crime were in possession of the persons concerned and were likely to be dealt with in a manner frustrating confiscation. The Court also found that the attached immovable properties, though purchased before the scheduled offence, could be brought within attachment because the attachment was directed against the value of proceeds of crime already traced into the formal financial system and not confined only to the original asset in its first form. On the contention that the recorded reasons could not form part of the attachment order, the Court held that the statute and rules did not prohibit disclosure of such reasons in the order and that inclusion of the reasons did not by itself vitiate jurisdiction.

Outcome: The Court found no merit in the challenge to the provisional attachment order on the issues considered, but, to maintain judicial consistency, referred two questions concerning the confidentiality and disclosure of the recorded reasons to a larger bench and directed the matter to be placed before the Chief Justice for constitution of that bench.

Issues: Whether the petitioner was entitled to discharge from the money-laundering prosecution for want of prima facie material connecting her with the alleged offence.

Analysis: At the stage of discharge or framing of charge, the assessment is confined to whether the record discloses a prima facie case and raises strong suspicion; it does not permit a roving enquiry or weighing of evidence as at trial. The materials showed that, notwithstanding the claimed resignation from the trust, the petitioner signed the loan-sanction documents as a trustee, mortgaged property for the loan, and was linked to the alleged diversion and laundering of loan proceeds. These materials justified continuation of the prosecution.

Conclusion: The petitioner was not entitled to discharge; prima facie material supported the charge of money laundering.

Issues: Whether the petitioners were entitled to discharge from prosecution for money laundering on the ground that the predicate offences were allegedly unsustainable and the Special Judge had not separately addressed every defence.

Analysis: The allegations that proceeds from illegal granite mining were used to acquire immovable properties, if accepted at face value, disclosed the ingredients of money laundering. At the discharge stage, the enquiry is confined to whether the complaint and accompanying material disclose a prima facie case or strong suspicion; it does not extend to meticulous evaluation of evidence, adjudication of defences, or determination of the legitimacy of the assets and sources of income. The statutory presumptions and reverse burden concerning interconnected transactions and the legitimacy of assets are matters for trial. While the predicate proceedings remain pending, the Special Court cannot determine their correctness or sustainability; that question lies with the competent court trying those offences. An order is not defective merely because it does not separately answer each contention when it identifies and applies the determinative legal issue. The restoration of the predicate prosecution further supported continuation of the money-laundering proceedings.

Conclusion: The petitioners were not entitled to discharge; sufficient prima facie material existed to proceed with the prosecution under the Prevention of Money Laundering Act, 2002.

Issues: (i) whether the subsequent committee report dated 31.03.2021 furnished a ground to quash the criminal proceedings and PMLA complaint; (ii) whether the proceedings against the women accused could be quashed for want of incriminating material; (iii) whether delay in registration of the criminal case, alleged mala fides, and the plea that witness statements were merely stereotyped versions justified quashing; and (iv) whether the PMLA prosecution could be terminated on the basis that the predicate offences were disputed or not finally established.

Issue (i): whether the subsequent committee report dated 31.03.2021 furnished a ground to quash the criminal proceedings and PMLA complaint;

Analysis: The report was prepared for the limited purpose of assessing damages in recovery proceedings and did not determine criminal liability. The report was disputed, not accepted by the Government, and its evidentiary value, correctness, and admissibility were matters for trial. The existence or non-existence of civil recovery proceedings, or the acceptance of any committee report, would not by itself extinguish the criminal prosecution arising from the alleged illegal quarrying and laundering of proceeds.

Conclusion: The report dated 31.03.2021 did not justify quashing of the proceedings.

Issue (ii): whether the proceedings against the women accused could be quashed for want of incriminating material;

Analysis: The materials on record prima facie disclosed that the women accused were partners in the quarrying concern during the relevant period and were connected with the alleged illegal mining operations. Their later retirement from the firm did not erase possible liability for acts committed during the period of active association. The question of their exact role and participation required appreciation of evidence at trial.

Conclusion: The proceedings against the women accused were not liable to be quashed on that ground.

Issue (iii): whether delay in registration of the criminal case, alleged mala fides, and the plea that witness statements were merely stereotyped versions justified quashing;

Analysis: The allegations related to continuing and large-scale economic offences involving illegal quarrying, damage to public property, and alleged laundering of proceeds. In such a setting, delay in registration was not by itself fatal. Allegations of mala fides and the contention based on similarity of statements under Section 161 CrPC raised disputed factual questions and could not be decided in proceedings under Section 482 CrPC. The Court was not required to conduct a mini trial at the quash stage.

Conclusion: These grounds did not warrant interference.

Issue (iv): whether the PMLA prosecution could be terminated on the basis that the predicate offences were disputed or not finally established;

Analysis: The offence under the Prevention of Money Laundering Act, 2002 is distinct and independent. Once the complaint and accompanying materials disclosed prima facie proceeds of crime and laundering activity, the Court could not quash the prosecution merely because the accused disputed the predicate offences. The burden and evidentiary issues under the Act were matters for trial, and the existence of multiple surviving scheduled offences meant that the substratum of the PMLA case remained intact.

Conclusion: The PMLA proceedings were maintainable and not liable to be quashed.

Final Conclusion: The Court declined to exercise inherent jurisdiction to interfere with the criminal revisions and quash petitions, holding that the materials disclosed a prima facie case fit for trial and that all disputed factual and evidentiary issues must be resolved by the trial court.

Ratio Decidendi: Inherent jurisdiction under Section 482 CrPC cannot be used to quash criminal proceedings where the allegations disclose a prima facie case, the issues turn on disputed facts and evidence, and the PMLA prosecution is founded on surviving scheduled offences and alleged proceeds of crime.

Issues: Whether the petitioner established a case of unlawful assault, coercion and denial of legal access during examination under Section 50 of the Prevention of Money-Laundering Act, 2002, so as to warrant judicial relief and preservation of the alleged CCTV material.

Analysis: The allegations rested primarily on the petitioner's assertions and subsequent medical documents. The Court found no independent contemporaneous material conclusively linking the alleged injuries to the proceedings on 20.04.2026. The respondents denied the allegations and relied on CCTV material and the Incident Report of the same date, which indicated that the petitioner left the premises without visible injury. The Court also noted that no immediate complaint of assault or request for medical aid was shown to have been made at the premises. On the material before it, the Court was not persuaded to accept the claim of physical assault or coercion.

Conclusion: The petitioner failed to establish the alleged illegal assault or coercion, and the request for relief was rejected.

Issues: Whether a writ of mandamus can be issued directing the Enforcement Directorate to initiate proceedings under the Prevention of Money Laundering Act, 2002 or register an ECIR merely because a predicate offence is alleged and a departmental circular suggests action above a monetary threshold.

Analysis: The initiation of proceedings under the Prevention of Money Laundering Act, 2002 depends upon the Authorized Officer's satisfaction, based on materials in possession and recorded reasons to believe, as to the existence of proceeds of crime. The existence of a predicate offence does not, by itself, compel registration of an ECIR or initiation of enforcement action. An internal departmental circular cannot override the statutory scheme. The request for coercive directions was also unsustainable because persons likely to be affected by such directions were not impleaded. A writ of mandamus cannot be issued to compel an authority to exercise a discretionary statutory function in a particular manner.

Conclusion: The prayer for a direction to initiate proceedings under the Prevention of Money Laundering Act, 2002 was rejected, and the writ petition was dismissed.