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2023 (9) TMI 1479 - DELHI HIGH COURT Money Laundering

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Equivalent-value attachment may be substituted with FDRs where the properties are not alleged proceeds of crime.
Where attachment concerns property of equivalent value rather than proceeds of crime, substitution with fixed deposit receipts may be accepted if it preserves the enforcement interest. The Delhi HC distinguished between assets said to represent proceeds of crime and assets attached only to secure equivalent value, and noted the continuing burden of keeping unused land and buildings under attachment. It accepted the applicants' offer to furnish FDRs of equal value, supported by an undertaking that the Enforcement Directorate would have a lien and could encash the FDRs if the appeal succeeds. The attached properties were therefore directed to be released on those conditions.

Status quo - attachment of property - proceeds of crime - amount equivalent to proceeds of crime - substitution of attached property with FDR - PMLA rules on acceptance of FDRs - change of circumstancesStatus quo - attachment of property - substitution of attached property with FDR - Whether the properties attached of respondent Nos.16 and 17 may be released despite the interim status quo order and the objections raised by the Enforcement Directorate - HELD THAT: - The Court noted that the interim status quo order of 21.03.2018 continued and that CRL.L.P. 184/2018 is pending. The attached properties are land and buildings of the companies and were not shown to be the actual "proceeds of crime" but properties of equivalent value. Having considered that the properties are deteriorating and that the applicants offered substitution by bank guarantees in the form of FDRs, the Court observed the distinction between attachment of actual proceeds of crime and attachment of property of equivalent value; substitution may be permissible in the latter situation. Although the ED relied on the PMLA rule contended to restrict acceptance of FDRs to certain joint-ownership scenarios and invoked the principle that a statutory mode must be followed, the Court exercised its equitable jurisdiction under Section 482 CrPC and, in the interest of justice, permitted release of the specified properties on strict conditions. The Court directed deposit of FDRs in the name of the respective company with the Additional Director, ED, with a lien in favour of the ED, an undertaking that the ED may encash the FDRs if it succeeds in appeal, prohibition on creating charges or loans against the FDRs, and renewal of the FDRs as required by law, while clarifying that this interim direction does not express any view on merits. [Paras 11, 12, 13, 14, 15]The properties of respondent Nos.16 and 17 are released on furnishing FDRs in the companies' names, deposited with the Additional Director, ED subject to a lien and undertakings as directed; the application is disposed of.Final Conclusion: The application under Section 482 CrPC is allowed insofar as the release of the attached properties of respondent Nos.16 and 17 is concerned on the conditions directed (deposit of FDRs with lien, undertakings and renewal); no determination on merits of the underlying criminal appeal is recorded.

2023 (9) TMI 1070 - DELHI HIGH COURT Money Laundering

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Appeal Dismissed: Single-Member Bench Permissible, PAO Valid, Writ Petition Not Maintained Due to Unexhausted Remedies.
The HC dismissed the appeal, supporting the Single Judge's decision. It upheld the validity of the Adjudicating Authority's order and the PAO, confirming that a single-member bench is permissible. The HC found the PAO contained sufficient reasons, and the writ petition was not maintainable, as statutory remedies were not exhausted.

Validity of single member bench under Section 6 - constitution and quorum of the Adjudicating Authority - power of the Chairperson to constitute Benches including single member Benches - Section 6(7) reference to a larger Bench and transfer by the Chairperson - requirement of "reason to believe" for provisional attachment - no obligation to record separate reasons for each attached property - maintainability of writ petition in presence of statutory alternative remedy - availability of appeal under Section 26Validity of single member bench under Section 6 - constitution and quorum of the Adjudicating Authority - power of the Chairperson to constitute Benches including single member Benches - Whether the Adjudicating Authority could validly hear the matter through a single member Bench and whether the quorum was incomplete. - HELD THAT: - The Court held that Section 6 envisages an Adjudicating Authority consisting of a Chairperson and two other members but, read with Section 6(5)(b) and the statutory scheme, a "Bench" may consist of one or two members and therefore a single member Bench is permissible. Reliance was placed on the Division Bench decision in J Sekar which construed the word "Bench" as not necessarily connoting plurality and recognised constitution of single member Benches. Applying that principle, the challenge that the quorum was incomplete and that the Chairperson sitting singly gave rise to coram non judice was rejected. [Paras 11, 12]The composition objection was rejected and a single member Bench was held to be valid.Section 6(7) reference to a larger Bench and transfer by the Chairperson - Whether an applicant may file an application under Section 6(7) to require constitution of a two member Bench at the nascent stage and whether the Adjudicating Authority erred in rejecting such application without hearing. - HELD THAT: - Section 6(7) permits the Chairperson or a Member to refer or transfer a matter to a Bench of two Members if it appears that the case ought to be so heard. The Court observed that Section 6 does not contemplate an adversarial remedy of filing a preliminary application to insist on constitution of a two member Bench; rather, the Chairperson is empowered to constitute or transfer matters as he deems fit during the course of adjudication. On the facts the matter was at a nascent stage and the material did not show that the matter was of such a nature that it ought to be heard by two Members; the application was therefore not maintainable. [Paras 13, 14, 15]The application under Section 6(7) was not maintainable and the Adjudicating Authority did not err in declining to refer the matter to a two member Bench.Requirement of "reason to believe" for provisional attachment - no obligation to record separate reasons for each attached property - Whether the Provisional Attachment Order was vulnerable for lack of "reason to believe" and whether separate reasons had to be recorded for each property attached. - HELD THAT: - The Court examined the Provisional Attachment Order and the supporting complaint and materials (including FIR, bank complaint, forensic audit, ECIR and witness statements) and found that the Deputy Director had recorded adequate reasons to believe that the appellant was in possession of proceeds of crime and that such proceeds were likely to be concealed or dealt with. The Court held that PMLA does not require a separate "reason to believe" to be recorded for each property attached; the PAO and complaint collectively demonstrated the requisite substantive satisfaction under Section 5 and did not attract interference under Article 226. [Paras 7, 8, 9]The Provisional Attachment Order contained sufficient reasons to believe and did not require separate reasons for each attached property; no interference was warranted.Maintainability of writ petition in presence of statutory alternative remedy - availability of appeal under Section 26 - Whether the writ petition under Article 226 challenging the Adjudicating Authority's order was maintainable when a statutory appeal to the Appellate Tribunal under Section 26 was available. - HELD THAT: - The Court applied the well settled rule that where a statute provides an efficacious alternative remedy, writ jurisdiction should normally not be invoked to bypass the statutory remedy. The Act provides an appeal to the Appellate Tribunal under Section 26; an Appellate Tribunal was functioning when the impugned order was passed. While recognising limited exceptions to this rule (for example, patent violation of fundamentals of judicial procedure or denial of natural justice), the Court found no such exceptional circumstances on the record sufficient to displace the statutory remedy. Therefore the writ petition was held not maintainable. [Paras 16, 17, 18]The writ petition was not maintainable in view of the availability of appeal under Section 26; the High Court will not ordinarily entertain Article 226 where an effective statutory remedy exists.Final Conclusion: The Division Bench dismissed the Letters Patent Appeal and upheld the Single Judge's order confirming the Adjudicating Authority's order dated 25.01.2023: the single member Bench was valid, the PAO contained sufficient "reason to believe", the Section 6(7) application was not maintainable at that stage, and the writ petition was barred by the availability of an effective statutory appeal under Section 26.

2023 (9) TMI 1069 - ALLAHABAD HIGH COURT Money Laundering

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Independent money-laundering proceedings survive conditional pardon in the scheduled offence; quashing of cognizance was refused.
Grant of pardon to an approver in the scheduled offence did not by itself bar continuation of proceedings under the Prevention of Money Laundering Act, 2002, because money-laundering is an independent offence tied to the process or activity involving proceeds of crime. The protection available where a person has been finally discharged, acquitted, or otherwise absolved in the predicate offence was not available to a mere approver, since pardon under Section 306 of the Code of Criminal Procedure, 1973 is conditional and not a finding of innocence. The request to invoke Section 482 of the Code for quashing the cognizance and summoning order was therefore rejected.

Effect of grant of pardon under Section 306 Cr.P.C. on collateral proceedings - Money laundering as an independent/stand alone offence under Section 3 of the Prevention of Money Laundering Act - Requirement of being "finally absolved" by discharge, acquittal or quashing to preclude PMLA action - Approver/pardon regime and its object to elicit full and true disclosure - Power of the Court under Section 482 Cr.P.C. to quash criminal proceedings - sparing exerciseEffect of grant of pardon under Section 306 Cr.P.C. on collateral proceedings - Money laundering as an independent/stand alone offence under Section 3 of the Prevention of Money Laundering Act - Requirement of being "finally absolved" by discharge, acquittal or quashing to preclude PMLA action - Approver/pardon regime and its object to elicit full and true disclosure - Whether grant of pardon to the applicant under Section 306 Cr.P.C. in the scheduled offence precludes continuation of proceedings against him under the Prevention of Money Laundering Act (PMLA) - HELD THAT: - The Court held that grant of pardon under Section 306 Cr.P.C. to an accomplice/approver is qualitatively different from an order of discharge, acquittal or quashing of the scheduled offence. Pardon is tendered to a person "supposed to have been directly or indirectly concerned in or privy to an offence" to secure his full and true disclosure so as to bring home the guilt of other accused; on acceptance he ceases to be an accused in the pardoned proceeding and is examined as a witness, subject to the condition of disclosure and subject to revocation under Section 308 if the condition is not complied with. The Supreme Court's dictum in Vijay Madanlal Chaudhary that a person "finally absolved by a Court of competent jurisdiction" cannot be proceeded against under PMLA applies to persons who are discharged, acquitted or whose criminal case is quashed. That principle does not, in the facts of this case, extend to a person merely granted pardon under Section 306, because such pardon presupposes involvement in the scheduled offence rather than a finding of no case or innocence. Consequently, a pardon in the scheduled offence does not ipso facto result in acquittal under the PMLA; the accused would have to obtain pardon in respect of the PMLA proceedings as well by making full and true disclosure relating to processes or activities connected with proceeds of crime. The Court therefore found no illegality in the cognizance/summoning order and declined to quash PMLA proceedings on the basis of the earlier pardon. [Paras 46, 48, 52, 53, 56]Grant of pardon under Section 306 Cr.P.C. in the scheduled offence does not, by itself, bar prosecution under PMLA; the quashing prayer was rejected and PMLA proceedings sustained.Power of the Court under Section 482 Cr.P.C. to quash criminal proceedings - sparing exercise - Whether the exercise of inherent jurisdiction under Section 482 Cr.P.C. warrants quashing of the cognizance/summoning order and related proceedings in the PMLA complaint case - HELD THAT: - Applying the established principle that the power under Section 482 Cr.P.C. must be exercised sparingly and only to secure the ends of justice, the Court observed that accepting the applicant's contention would permit a person accused of money laundering to avoid trial without seeking pardon in the PMLA proceedings and without making the statutory full and true disclosure required under Section 306. Given that the applicant has not been finally absolved by discharge, acquittal or quashing of the scheduled offence, and in view of the legislative purpose and judicial exposition of the approver/pardon scheme, there was no ground to exercise the inherent jurisdiction to quash the PMLA complaint or the summoning order. The application under Section 482 Cr.P.C. was accordingly held to lack merit. [Paras 57, 58]Inherent jurisdiction under Section 482 Cr.P.C. not exercised; application to quash dismissed.Final Conclusion: The petition under Section 482 Cr.P.C. is dismissed: the grant of pardon under Section 306 Cr.P.C. in the scheduled offence does not automatically bar prosecution under the PMLA, and there is no illegality in the cognizance/summoning order impugned.

2023 (9) TMI 1456 - PATNA HIGH COURT Money Laundering

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Patna HC rejects anticipatory bail in money laundering case for knowingly handling proceeds of crime under Section 45(1)(ii) PMLA
Patna HC rejected petitioner's anticipatory bail application in money laundering case involving proceeds of crime and fund siphoning. Court found petitioner knowingly involved in acquisition, concealment and transfer of proceeds of crime. Under Section 45(1)(ii) PMLA, bail requires court satisfaction that accused is not guilty and unlikely to commit offence while on bail. Court noted coordinate bench had rejected similar applications of co-accused in related matter, finding no grounds for granting anticipatory bail.

2023 (9) TMI 1101 - GAUHATI HIGH COURT Money Laundering

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Issues: Whether the writ petitions challenging the provisional attachment orders and connected proceedings under the Prevention of Money Laundering Act, 2002 were liable to be interfered with in exercise of writ jurisdiction, and whether the petitioners had made out a case of lack of jurisdiction, absence of reasons to believe, or other patent illegality in the initiation and continuation of the PMLA proceedings.

Analysis: The challenge was examined in the context of the limited scope of judicial review under Article 226 of the Constitution of India. The materials placed before the authority were found to include information regarding the functioning of the University, the grant of degrees alleged to be fake, and the withdrawal and closure of the endowment fund account, which constituted a factual basis for the competent authority to form the requisite satisfaction. The proceedings were also at an intermediate stage under the PMLA, and the reliefs sought were considered pre-emptive in nature. The Court further noted that the matter involved numerous disputed questions of fact, which could not be conveniently adjudicated in writ jurisdiction. Reliance on later developments and rival versions regarding legality of the University's functioning and the validity of degrees did not dislodge the existence of material supporting the impugned action. The Court also treated the earlier judicial findings on the University's functioning and degrees as relevant background against which the PMLA proceedings were founded.

Conclusion: The challenge to the provisional attachment orders and connected PMLA proceedings was not made out. The initiation of proceedings was not shown to suffer from a patent jurisdictional error or absence of material, and interference under Article 226 was declined.

Final Conclusion: The writ court declined to interdict the ongoing money-laundering proceedings and upheld the restraint against disturbing the provisional attachment at that stage, leaving the parties to pursue the statutory process and remedies available under the Act.

Ratio Decidendi: In a writ petition under Article 226, provisional attachment and related PMLA proceedings will not be interfered with at a premature stage where the competent authority has some material to form the requisite satisfaction and the dispute turns substantially on contested facts rather than a clear jurisdictional defect.

PMLA provisional attachment in writ jurisdiction declines interference where the authority had material and disputes were factual and premature.
Under Article 226, provisional attachment and related PMLA proceedings will not ordinarily be interfered with at a premature stage where the competent authority had material to form the requisite satisfaction. The challenge was found to rest largely on disputed questions of fact concerning the University's functioning, alleged fake degrees, and the endowment fund account, which were not suitable for writ adjudication. Earlier judicial findings on those matters were treated as relevant background supporting the impugned action. As no patent jurisdictional defect, absence of reasons to believe, or clear illegality was established, interference in writ jurisdiction was declined and the parties were left to pursue the statutory process under the Act.

Provisional attachment under the Prevention of Money Laundering Act, 2002 - reasons to believe - proceeds of crime - jurisdictional error - judicial review of the decision making process - writ jurisdiction under Article 226 of the Constitution - predicate offence and distinctness of PMLA proceedings - interim order vacatedProvisional attachment under the Prevention of Money Laundering Act, 2002 - reasons to believe - proceeds of crime - jurisdictional error - Validity of the provisional attachment orders and whether the authorities had 'reasons to believe' so as to assume jurisdiction under the PMLA - HELD THAT: - The Court held that the provisional attachment orders were preceded by a subjective satisfaction by the competent authority based on information available regarding unauthorised running of the university, alleged award of fake degrees, withdrawal and closing of the endowment account and other material facts. These factors constituted relevant material on which the authority could form 'reasons to believe' and thereby assume jurisdiction under the Act. The petitioners, seeking pre emptive relief at an interlocutory stage, were required to make out that there was a jurisdictional error or blatant violation of the statute; they failed to discharge this higher burden. The Court confined its scrutiny to the decision making process and concluded that no prima facie illegality or absence of material vitiated the attachment orders. [Paras 61, 62, 63, 75]The provisional attachment orders were not shown to be prima facie bad in law for want of 'reasons to believe'; no jurisdictional error was established and the challenge to the attachments failed.Judicial review of the decision making process - writ jurisdiction under Article 226 of the Constitution - disputed questions of fact - Whether the writ court should interfere at the interlocutory stage where disputed questions of fact predominate - HELD THAT: - The Court reiterated that judicial review examines the decision making process and not the merits, and that when the controversy raises numerous disputed factual questions a writ court should not embark on resolving those factual disputes. Given the multiplicity of contested factual issues in this matter (establishment and functioning of the university, validity of degrees, deposits and withdrawals, existence of campus and endowment account conduct), the Court declined to entertain pre emptive relief which would require resolution of factual disputes more appropriately tried in the statutory forums and proceedings under the PMLA. [Paras 62, 63, 74, 75]Writ interference was inappropriate at this stage because the core issues involved disputed questions of fact and the Court must confine itself to reviewing the decision making process.Predicate offence and distinctness of PMLA proceedings - proceedings under the Prevention of Money Laundering Act, 2002 - Whether a stay of the predicate offence automatically requires abeyance of the PMLA proceedings - HELD THAT: - The Court observed that investigation and trial under the PMLA operate independently and are distinct from the police (predicate) investigation. A stay of proceedings in the predicate offence does not necessarily and automatically stay PMLA proceedings. The authorities are entitled to proceed under the provisions of the PMLA, subject to the due process and statutory safeguards, and the existence of a stay in the predicate matter does not by itself invalidate actions taken under the PMLA. [Paras 48, 49, 75]Stay of the predicate offence did not per se require the PMLA proceedings to be kept in abeyance; the PMLA actions could continue subject to statutory process.Final Conclusion: Both writ petitions were dismissed for lack of prima facie merit; the interim directions granted earlier are vacated. The documents (title deeds and indemnity bond) deposited in court registry are to be returned to the petitioners through their counsel. No order as to costs.

2023 (9) TMI 1379 - MADRAS HIGH COURT Money Laundering

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Issues Involved:
1. Whether the proceedings under the Prevention of Money-Laundering Act, 2002 (PMLA) can continue after the closure of the predicate offence.
2. Interpretation and application of the principles laid down in Vijay Madanlal Choudhary case.

Summary of Judgment:

Issue 1: Continuation of PMLA Proceedings Post Predicate Offence Closure
The petitioner sought a direction to close proceedings against them under the Enforcement Case Information Report (ECIR) linked to an FIR which had been closed by the jurisdictional Metropolitan Magistrate Court. The petitioner argued that, according to the Supreme Court's ruling in Vijay Madanlal Choudhary, authorities under PMLA cannot prosecute if the predicate offence has been closed. The court noted the closure of the predicate offence and its finality, emphasizing that there can be no money laundering offence without an active predicate offence. This was supported by precedents such as S. Jagathrakshakan and Harish Fabiani cases, which reiterated that PMLA proceedings cannot survive the closure of the predicate offence.

Issue 2: Application of Vijay Madanlal Choudhary Principles
The court referenced the Supreme Court's decision in Vijay Madanlal Choudhary, particularly paragraph 467(v)(d), which states that money laundering charges cannot proceed if the predicate offence is closed or the accused is acquitted. The court also cited relevant case laws, including Emta Coal, where similar issues were addressed, and the Supreme Court's order affirmed that PMLA proceedings cannot continue post-closure of the predicate offence unless further action is taken on the predicate offence.

Final Order:
The court disposed of the writ petition, ruling in favor of the petitioner and directing the closure of PMLA proceedings. However, it included a caveat that if any further action is taken regarding the predicate offence, the Enforcement Directorate retains the right to revive the proceedings under PMLA. This decision aligns with the Supreme Court's stance in Emta Coal's case. There was no order as to costs.

Court directs closure of PMLA proceedings after predicate offence, citing legal precedents.
The court ruled in favor of the petitioner, directing the closure of proceedings under the Prevention of Money-Laundering Act (PMLA) following the closure of the predicate offence. The court emphasized that PMLA proceedings cannot continue if the predicate offence has been closed, citing precedents and the principles established in the Vijay Madanlal Choudhary case. The Enforcement Directorate retains the right to revive the PMLA proceedings if further action is taken on the predicate offence, in line with the decision in Emta Coal's case. No costs were awarded in this disposition.

Finality of closure of predicate offence - Effect of closure/quashing of scheduled offence on prosecution under the Prevention of Money Laundering Act - Dependence of offence under PMLA on property being proceeds of crime - Stand alone offence argument under PMLA - Preservation of liberty to revive PMLA proceedings if predicate offence is reopenedFinality of closure of predicate offence - Effect of closure/quashing of scheduled offence on prosecution under the Prevention of Money Laundering Act - Dependence of offence under PMLA on property being proceeds of crime - Whether proceedings under the PMLA can continue after the predicate (scheduled) offence has been finally closed/quashed. - HELD THAT: - The Court applied the principle that an offence under Section 3 of the PMLA is dependent on illegal gain derived from criminal activity relating to a scheduled offence and that PMLA authorities cannot proceed on a notional assumption that a scheduled offence has been committed, as stated in Vijay Madanlal Choudhary and reiterated in Parvathi Kollur . The Court observed that in the present matter the predicate offence has been closed and that this closure has attained finality (paragraph 10). Having regard to the consistent view in Jagathrakshakan , Harish Fabiani , and the reasoning in Emta Coal , the Court concluded that PMLA proceedings could not be permitted to continue where the predicate offence has been finally closed/quashed. The Court noted the limited contention and authorities on the 'stand alone offence' point and recognized the caveat recorded by the Supreme Court in its disposal of the Special Leave Petition in Emta Coal, namely that liberty must be preserved to the Enforcement Directorate to revive proceedings if further action is taken in respect of the predicate offence (paragraph 18). The Court therefore acceded to the writ petition while expressly preserving the ED's right to take further steps under the PMLA should the predicate proceedings be reopened or further action occur. [Paras 10, 18, 19]Writ petition allowed: proceedings arising from the ECIR in question are set aside in view of the final closure of the predicate offence, subject to the caveat preserving the Enforcement Directorate's liberty to revive PMLA proceedings if further action is taken in respect of the predicate offence.Final Conclusion: The petition is allowed: having found that the predicate offence has been finally closed, the Court set aside the PMLA proceedings arising from the ECIR, while expressly preserving the respondent's right to revive proceedings if the predicate offence is thereafter re opened or further action is taken.

2023 (9) TMI 1473 - KERALA HIGH COURT Money Laundering

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Regular bail under PMLA granted where predicate offences were unproven and twin conditions for release were satisfied.
Regular bail under section 45 of the Prevention of Money Laundering Act, 2002 was granted because the Court found reasonable grounds to believe that the accused was not guilty and was unlikely to reoffend. The predicate offences, mainly under sections 420 and 421 of the Indian Penal Code, 1860, had not been independently established, and cheating under section 420 requires dishonest or fraudulent intention from the inception. The statutory presumption under section 24 of the PMLA did not create a presumption of guilt for the predicate offences, and the materials relied on were insufficient to justify denial of bail at that stage. The accused's age, prolonged custody, attachment of properties, surrender of passport, and low risk of repetition also supported bail.

Regular bail under section 45 of the PML Act - Twin conditions for bail under section 45 of the PML Act - Predicate offence requirement for prosecution under the PML Act - Dishonest intention requirement for section 420 IPC - Presumption under section 24 of the PML Act is evidentiary and not a presumption of guilt for predicate offences - Admissibility and use of statements recorded under section 50 of the PML Act - Default bail under section 167 Cr.P.C. (procedural safeguard)Regular bail under section 45 of the PML Act - Twin conditions for bail under section 45 of the PML Act - Predicate offence requirement for prosecution under the PML Act - Dishonest intention requirement for section 420 IPC - Petitioner entitled to regular bail under section 45 of the PML Act. - HELD THAT: - The Court applied the twin-condition test in section 45 of the PML Act and concluded there are reasonable grounds to believe the accused is not guilty of the offence of money laundering and there is no possibility of his committing similar offences again. The predicate offences principally relied upon were under sections 420 and 421 IPC; other statutory offences cited (BUDS Act, Kerala Depositors Act, RBI provisions) are not scheduled predicate offences for the PML Act. Dishonest or fraudulent intention necessary for section 420 IPC must exist from the inception; mere failure to repay or to perform after promise does not, prima facie, establish such intention. Section 24 of the PML Act creates only an evidentiary presumption about proceeds of crime that operates after foundational facts are proved and does not amount to a presumption of guilt for predicate offences. The predicate offences have been under investigation for several years without filing a final report; on the material before the Court (including the fact of prolonged investigation, prior payments/interest received by depositors until March 2020, attachment of properties, surrender of passport, and the petitioner's advanced age), the Court found it difficult to conclude guilt on the predicate offences at this stage. Having regard to the cumulative circumstances and precedents on bail, the Court held the twin conditions under section 45 are satisfied and granted regular bail subject to conditions. [Paras 28, 34, 35, 41, 42]Petitioner is entitled to be released on regular bail under conditions specified by the Court.Admissibility and use of statements recorded under section 50 of the PML Act - Presumption under section 24 of the PML Act is evidentiary and not a presumption of guilt for predicate offences - Statements purportedly obtained under section 50 of the PML Act cannot, at this stage, be relied upon to establish guilt for predicate offences under the Indian Penal Code. - HELD THAT: - The Court observed that statements obtained under section 50 of the PML Act are not admissible under the Indian Evidence Act for the purpose of proving guilt on predicate IPC offences; even if admissible under the PML Act, such statements cannot substitute for the independent proof required to establish the ingredients of the predicate offences (notably dishonest intention for section 420 IPC). The question whether particular statements truly qualify as statements under section 50 of the PML Act was left open for determination at the appropriate stage. [Paras 26, 33]The statements relied upon by the prosecution cannot be used at this stage to establish the petitioner's guilt for the predicate IPC offences.Default bail under section 167 Cr.P.C. (procedural safeguard) - The question of statutory/default bail under section 167 Cr.P.C. is rendered academic in the context of this order and is not further adjudicated. - HELD THAT: - While issues were raised about the timing and filing of the complaint vis-a -vis the statutory time-limits for default bail, the Court noted earlier authoritative observations condemning the practice of using incomplete reports to defeat default bail. However, given the length of custody already undergone by the petitioner (over nineteen months) and the nature of the present bail determination, the Court treated the default-bail issue as academic and did not decide it. [Paras 18]Default-bail contention not decided as it is academic for present purposes.Final Conclusion: On application of the legal principles governing bail under the PML Act and having regard to the state of the predicate investigations, the petitioner was granted regular bail on conditions specified by the High Court; the observations are confined to the bail application and do not prejudice continuing investigations or other proceedings.

2023 (9) TMI 1258 - MADRAS HIGH COURT Money Laundering

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PMLA bail under twin statutory conditions was unsustainable where recorded satisfaction was absent and the order was passed in haste.
Bail under the Prevention of Money Laundering Act remains subject to the statutory twin conditions in Section 45, requiring the Court to be satisfied that the accused is not prima facie guilty and is not likely to commit any offence while on bail. An order granting bail without recorded satisfaction on those requirements, especially where the contemporaneous record shows haste and inadequate consideration of the statutory embargo, is legally vulnerable. On the stated facts, the bail order was unsustainable because the trial court did not properly address the PMLA restrictions before enlarging the accused on bail.

Grant of bail under PMLA and twin conditions in Section 45 - requirement of reasoned order for judicial pronouncement - docket order without prepared detailed judgment - preliminary satisfaction by court before releasing accused on bail - effect of incomplete predicate-offence investigation on bailRequirement of reasoned order for judicial pronouncement - docket order without prepared detailed judgment - Whether the trial Court erred in granting bail by a docket order pronounced on 16.08.2023 without a contemporaneously prepared reasoned judgment and in circumstances where the detailed order was not available immediately. - HELD THAT: - The High Court found that the trial Court had pronounced a docket order on 16.08.2023 enlarging the accused on bail and that, when records were called for the following day, no prepared detailed order was found in the trial Court records. The subsequent detailed order produced on 21.08.2023 did not indicate that a reasoned order had been dictated and signed at the time of pronouncement, and the absence of a contemporaneous prepared text raised suspicion about the propriety of the manner in which bail was granted. The Court relied on the principle that a judicial officer should not pronounce the operative portion of a judgment in open court without the entire text of the judgment being prepared/dictated, and observed that the deficit in procedure warranted interference by the High Court notwithstanding that administrative action may also be appropriate. Taking these defects into account, the High Court concluded that the manner of pronouncement and the lack of immediate availability of a reasoned order undermined the grant of bail. [Paras 2, 26]The bail order of 16.08.2023 was set aside on the ground that it was a docket order pronounced without a prepared reasoned judgment being available at the time of pronouncement.Grant of bail under PMLA and twin conditions in Section 45 - preliminary satisfaction by court before releasing accused on bail - effect of incomplete predicate-offence investigation on bail - Whether the trial Court properly recorded satisfaction as required by the PMLA regime (twin conditions) and whether delay or incompletion in the predicate-offence investigation by other agencies entitled the accused to bail. - HELD THAT: - The High Court examined the substance of the material on record, including prior orders of the High Court and the Supreme Court, the nature and gravity of the alleged money-laundering (involving numerous consignments and funds diverted abroad), ongoing steps by the Enforcement Directorate (including letters rogatory), and the accused's conduct in relation to cooperation with investigation. The Court noted that the detailed order produced did not demonstrate satisfaction of the twin conditions mandated by Section 45 of the PMLA Act, and found that delay in completion of predicate-offence investigation by DRI/CBI or closure of similar cases elsewhere cannot be presumed to establish the accused's innocence or constitute a ground mandating bail. The Court further observed risk factors such as the international connections of the accused, the alleged diversion of funds abroad, and the possibility of absconding or tampering, which weighed against release. Applying these considerations, the High Court concluded that the trial Court had not properly recorded the requisite satisfaction and that neither the pendency nor delay in predicate investigations entitled the accused to bail in the circumstances. [Paras 22, 23, 24, 26, 27]The High Court held that the trial Court failed to satisfy and record the twin conditions under Section 45 of PMLA before granting bail and rejected the contention that delay or incompletion of predicate investigations entitled the accused to bail; consequently the bail granted was set aside.Final Conclusion: The Criminal Original Petition filed by the Enforcement Directorate is allowed. The trial Court's order dated 16.08.2023 granting bail to the respondent is set aside for being a docket order pronounced without a contemporaneous reasoned judgment and for failure to record the requisite satisfaction under the twin conditions of Section 45 of the PMLA; connected miscellaneous petition closed.

2023 (9) TMI 662 - ALLAHABAD HIGH COURT Money Laundering

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Issues: (i) Whether the restrictions in Section 45 of the Prevention of Money Laundering Act, 2002 governed the High Court's power to grant anticipatory bail under Section 438 of the Code of Criminal Procedure, 1973. (ii) Whether dismissal of petitions under Section 482 of the Code of Criminal Procedure, 1973 concluded the question of anticipatory bail. (iii) Whether the applicants were entitled to anticipatory bail on the facts of the case.

Issue (i): Whether the restrictions in Section 45 of the Prevention of Money Laundering Act, 2002 governed the High Court's power to grant anticipatory bail under Section 438 of the Code of Criminal Procedure, 1973.

Analysis: The provisions of Sections 44 and 45 were read together and harmoniously. The saving of the High Court's special powers regarding bail was treated as having been placed in Section 44 by mistake and as intended to operate with Section 45. The Court relied on the structure of analogous statutes to hold that the legislative intent was not to curtail the constitutional court's power in the same manner as it restricts subordinate courts. It concluded that the rigours of Section 45 were not applicable to Constitutional Courts while deciding anticipatory bail.

Conclusion: The restrictions in Section 45 did not bar the High Court from considering anticipatory bail applications on their own merits.

Issue (ii): Whether dismissal of petitions under Section 482 of the Code of Criminal Procedure, 1973 concluded the question of anticipatory bail.

Analysis: The scope of quashing proceedings under Section 482 and the scope of bail jurisdiction were held to be distinct. The Court applied the principle that rejection of a quashing petition is not determinative of bail, and that anticipatory bail must be decided independently on its own facts. Prior rejection under Section 482 was therefore treated as not controlling the bail decision.

Conclusion: Dismissal of the Section 482 petitions did not preclude grant of anticipatory bail.

Issue (iii): Whether the applicants were entitled to anticipatory bail on the facts of the case.

Analysis: The Court considered the delay in lodging the complaints, the completion of investigation, the applicants' cooperation, the absence of recovery of proceeds of crime from them, the absence of attachment of their properties, and their personal circumstances, including age and ailments in the case of one applicant. It also noted that interim anticipatory bail had been operating without reported breach. On that basis, the Court found that continued protection was justified.

Conclusion: The applicants were entitled to anticipatory bail.

Final Conclusion: The interim protection was confirmed and the anticipatory bail applications were finally allowed, with the existing bail conditions to continue.

Anticipatory bail under PMLA was upheld as Section 45 restrictions did not bind the High Court's independent discretion.
Section 45 of the Prevention of Money Laundering Act did not restrict the High Court's power to consider anticipatory bail under Section 438 CrPC on its own merits, as the Court read Sections 44 and 45 harmoniously and held that the stringent restrictions were not meant to apply to Constitutional Courts. Dismissal of earlier Section 482 CrPC quashing petitions did not decide the bail question, because quashing and bail are distinct jurisdictions requiring independent consideration. On the facts, the Court relied on delay in lodging complaints, completion of investigation, cooperation by the applicants, absence of recovery or attachment, and continued compliance with interim protection to confirm anticipatory bail.

Anticipatory bail under Section 438 CrPC and restrictions of Section 45 of PMLA - Interpretation of Sections 44 and 45 of PMLA-saving of High Court's powers under Section 439 CrPC - Applicability of PMLA bail restrictions to Constitutional Courts - Distinction between quashing under Section 482 CrPC and grant of anticipatory bail - Principles for grant of bail in economic offences - Delay in prosecution and absence of recovery/attachment as factors in bailInterpretation of Sections 44 and 45 of PMLA-saving of High Court's powers under Section 439 CrPC - Applicability of PMLA bail restrictions to Constitutional Courts - Whether the restrictions in Section 45 of the PMLA operate to bar Constitutional Courts (High Courts) from exercising their special powers under Section 439 Cr.P.C. - HELD THAT: - The Court examined the placement and effect of Section 44(2) and Section 45 of the PMLA and, by harmonious construction, held that the provision saving the High Court's special powers under Section 439 Cr.P.C. (found in Section 44(2)) must be read with Section 45 so as to give effect to Parliament's intention. Noting the apparent misplacement (a "copy-paste error") which would otherwise render Section 44(2) redundant, the Court construed Sections 44 and 45 together so that the restrictions in Section 45 apply to Courts other than Constitutional Courts. Consequently, Constitutional Courts retain their special bail jurisdiction under Section 439 Cr.P.C. and need not apply the prima facie satisfaction requirement of Section 45 when deciding anticipatory bail applications under their inherent powers. [Paras 31, 32, 46, 50, 52]Sections 44 and 45 of the PMLA must be read harmoniously; the saving of High Court powers under Section 439 Cr.P.C. applies, and the restrictions in Section 45 do not fetter Constitutional Courts in exercising their bail jurisdiction.Distinction between quashing under Section 482 CrPC and grant of anticipatory bail - Anticipatory bail under Section 438 CrPC and restrictions of Section 45 of PMLA - Whether dismissal of petitions under Section 482 Cr.P.C. (quashing of charge-sheets/FIRs) conclusively establishes prima facie guilt and precludes grant of anticipatory bail. - HELD THAT: - The Court explained that the scope and standards of scrutiny under Section 482 (power to quash) are different from those applicable to anticipatory bail; a dismissal under Section 482 is not conclusive proof of prima facie guilt for the purpose of bail. Reliance on precedents (including Bhajan Lal, P. Chidambaram and subsequent authorities) led to the conclusion that anticipatory bail applications must be considered on their own merits and not disposed of merely because Section 482 petitions were rejected. The Court therefore rejected the submission that dismissal of quashing petitions establishes a bar to anticipatory bail. [Paras 53, 55, 56, 61, 63]Rejection of Section 482 petitions does not automatically preclude grant of anticipatory bail; the High Court must decide bail applications on their own merits.Principles for grant of bail in economic offences - Delay in prosecution and absence of recovery/attachment as factors in bail - Anticipatory bail under Section 438 CrPC and restrictions of Section 45 of PMLA - On the facts of these matters, whether interim anticipatory bail previously granted to the applicants should be confirmed. - HELD THAT: - The Court considered the nature of allegations (alleged diversion/sale of coal in breach of FSA), the long delay between the joint inspection/FIRs and filing of ED complaints (7-12 years), absence of recovery of proceeds of crime from the applicants and absence of attachment of their properties, cooperation of the applicants with investigation, medical/age-related infirmity of one applicant, and lack of any pointed material showing risk of tampering/witness intimidation. Applying established bail principles in economic offences and bearing in mind that Constitutional Courts retain their special bail powers, the Court found that the circumstances justified confirmation of the interim anticipatory bail orders. All interim conditions previously imposed were to continue and no fresh bonds were required as bonds were already furnished. [Paras 66, 70, 71, 73, 74]Interim anticipatory bail granted earlier is confirmed for all applicants; conditions of interim orders continue and no fresh bail bonds are required.Final Conclusion: The High Court construed Sections 44 and 45 of the PMLA harmoniously to preserve the High Court's special bail jurisdiction under Section 439 Cr.P.C., held that rejection of Section 482 petitions does not preclude grant of anticipatory bail, and on the facts (delay in prosecution, cooperation, absence of recovery/attachments, age/health and other circumstances) confirmed interim anticipatory bail for the applicants subject to the existing conditions.

2023 (9) TMI 661 - ORISSA HIGH COURT Money Laundering

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Non-bailable warrant requires recorded reasons before bypassing summons or a bailable warrant; absence of reasons makes it unsustainable.
A non-bailable warrant should not be issued at the first instance without recorded reasons showing that summons or a bailable warrant would be ineffective or that the accused was deliberately evading process. In complaint proceedings, summons is ordinarily the first process and a bailable warrant is generally the next step before resorting to a non-bailable warrant. Because the impugned order gave no reason for bypassing the lesser process, the exercise of discretion was vulnerable. The gravity of the alleged economic offence could not justify the warrant where no independent basis had been recorded. The non-bailable warrant was therefore held unsustainable and interference was warranted.

Non-bailable warrant - bailable warrant - personal liberty - exercise of judicial discretion in issuance of warrants - issuance of process for securing attendance - gravity of economic offences / money launderingNon-bailable warrant - bailable warrant - exercise of judicial discretion in issuance of warrants - personal liberty - gravity of economic offences / money laundering - Validity of the trial Court's issuance of non-bailable warrants (NBW) against the petitioners for non appearance and the appropriate process that ought to have been adopted to secure their attendance. - HELD THAT: - The Court examined the order sheet and facts: summons were issued after cognizance under the PML Act, the accused initially appeared through counsel and sought adjournments, and on several dates proceedings were also stalled due to Bar abstentions. On 20.04.2023 no steps were taken on behalf of the accused and the trial Court issued NBW. Applying the principle in Inder Mohan Goswami (that NBWs interfere with personal liberty and should not be issued mechanically and that ordinarily summons or bailable warrants should precede NBWs unless there is reason to believe the accused will evade process, tamper with evidence, or otherwise pose a risk), the High Court found no reasons recorded in the impugned order to justify issuance of NBWs at the first instance. Reliance on the general gravity of economic offences was not reflected in the trial Court's reasoning and therefore could not sustain the NBWs. Given there was nothing on record to show deliberate evasion by the accused, the judicious course would have been to issue bailable warrants before resorting to NBWs. The Court therefore held the impugned order issuing NBWs to be unsustainable, while directing that the accused should physically surrender and seek bail, to be granted on such terms as the trial Court may impose. [Paras 6, 8, 10, 11, 12]The NBWs issued by the trial Court are quashed; petitioners shall physically surrender before the trial Court and may move for bail, and on such application they shall be released on bail subject to terms as the trial Court deems fit; the CRLMCs are allowed.Final Conclusion: The High Court set aside the non bailable warrants as issued without proper application of mind and without recorded reasons; it directed the petitioners to surrender and permitted them to seek bail, and allowed the Criminal Miscellaneous Cases.

2023 (9) TMI 725 - TELANGANA HIGH COURT Money Laundering

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PMLA proceedings depend on a scheduled offence and proceeds of crime; acquittal without illicit gains bars continuation.
Proceedings under the Prevention of Money-Laundering Act, 2002 cannot continue where the scheduled offence has ended in acquittal and the record does not show generation or possession of proceeds of crime. The Court applied the settled principle that liability under Section 3 depends on the existence of a scheduled offence and illicit gain arising from criminal activity. Relying on Vijay Madanlal Choudhary as binding under Article 141, it noted that the related proceedings against the person through whom the alleged benefit was derived had also been quashed for want of criminal proceeds. On those facts, continuation of PMLA proceedings was impermissible.

Predicate offence acquittal and effect on PMLA proceedings - Dependence of money laundering offence on illegal gain from scheduled offence - Limitation on Enforcement Directorate to investigate/prosecute on a notional assumption of scheduled offence - Quashing of PMLA/ED proceedings where no proceeds of crime are found - Doctrine of stare decisis under Article 141 of the ConstitutionPredicate offence acquittal and effect on PMLA proceedings - Dependence of money laundering offence on illegal gain from scheduled offence - Quashing of PMLA/ED proceedings where no proceeds of crime are found - Whether the Enforcement Directorate's investigation in ECIR/HYZO/36/2020 could be continued against the petitioner when the predicate offence ended in acquittal and the court found that no criminal proceeds were generated. - HELD THAT: - The Court applied the binding principle laid down by the three Judge Bench in Vijay Madanlal Choudhary that an offence under Section 3 of the PMLA is dependent on illegal gain of property as a result of criminal activity relating to a scheduled offence, and authorities cannot prosecute on a notional basis or on the assumption that a scheduled offence has been committed. If the person connected with the scheduled offence is finally discharged/acquitted or the criminal case is quashed, there can be no money laundering offence against that person or anyone claiming the property linked to the scheduled offence through him. The Court noted that the predicate case ended in acquittal, that a related ECIR matter as to the alleged beneficiary was quashed by this Court on the ground that no crime proceeds were generated, and that subsequent proceedings against the petitioner alleged only facilitation/benefits from that acquitted person. While the Supreme Court (in a separate order) set aside the petitioner's anticipatory bail, the three Judge bench precedent on the interdependence of scheduled offence conviction and PMLA liability is binding under Article 141. Having found that no criminal proceeds were generated and that the predicate offence resulted in acquittal, the Court held that the authorities lacked jurisdiction to continue PMLA proceedings against the petitioner and that continuation would amount to an abuse of process. [Paras 20, 21]Proceedings in ECIR/HYZO/36/2020 against the petitioner are quashed.Final Conclusion: The criminal petition is allowed; the Enforcement Directorate proceedings in ECIR/HYZO/36/2020 dated 15.12.2020 against the petitioner are quashed on the ground that the predicate offence resulted in acquittal and no criminal proceeds were found, rendering continuation of PMLA proceedings impermissible under the binding precedent.

2023 (9) TMI 660 - TELANGANA HIGH COURT Money Laundering

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Issues: (i) whether Section 41-A of the Code of Criminal Procedure, 1973 applies to an arrest made under the Prevention of Money-Laundering Act, 2002; (ii) whether the remand rejection could be sustained on the ground that the arrest was unsupported by justifiable material; and (iii) whether the impugned order rejecting remand and the consequential claims for compensation and action against officers could stand.

Issue (i): whether Section 41-A of the Code of Criminal Procedure, 1973 applies to an arrest made under the Prevention of Money-Laundering Act, 2002.

Analysis: The statutory scheme of Section 19 of the Prevention of Money-Laundering Act, 2002 governs arrest by the authorised officer on the basis of material in possession, reason to believe, and recording of reasons in writing. The applicable legal position was that Section 41-A of the Code of Criminal Procedure, 1973 has no application to arrests under the Prevention of Money-Laundering Act, 2002.

Conclusion: The rejection of remand on the ground of non-compliance with Section 41-A of the Code of Criminal Procedure, 1973 was unsustainable.

Issue (ii): whether the remand rejection could be sustained on the ground that the arrest was unsupported by justifiable material.

Analysis: The Court held that the Designated Court had not adequately examined the material produced by the Enforcement Directorate in support of the arrest and had not considered the arrest question in the light of the later binding position on Section 19 of the Prevention of Money-Laundering Act, 2002. Since the remand order turned partly on an incomplete appraisal of the arrest material, fresh consideration was required.

Conclusion: The finding that the arrest was unsupported by justifiable material could not be sustained as the basis for refusing remand.

Issue (iii): whether the impugned order rejecting remand and the consequential claims for compensation and action against officers could stand.

Analysis: Once the remand rejection was found unsustainable, the matters relating to legality of arrest, compensation, and action under Section 62 of the Prevention of Money-Laundering Act, 2002 could not be finally determined at that stage and had to await fresh consideration by the Designated Court. The proper course was to remit the remand application for decision in accordance with law after hearing both sides.

Conclusion: The impugned order was set aside, the remand matter was sent back for fresh consideration, and the consequential claims were left to be worked out thereafter.

Final Conclusion: The proceedings resulted in a remand for fresh adjudication of the ED's remand request, with the earlier refusal to remand being displaced and the ancillary relief claims deferred to the outcome before the Designated Court.

Ratio Decidendi: Section 41-A of the Code of Criminal Procedure, 1973 does not govern arrests made under Section 19 of the Prevention of Money-Laundering Act, 2002, and the legality of such arrest must be assessed on the statutory requirements of Section 19 and the material placed before the competent court.

PMLA arrest procedure prevails over CrPC notice requirements, and remand must be tested on Section 19 material.
Section 41-A of the Code of Criminal Procedure does not apply to arrests made under Section 19 of the Prevention of Money-Laundering Act, because arrest under PMLA is governed by the authorised officer's possession of material, recorded reasons to believe, and written reasons under the special statute. The Telangana High Court also indicated that remand refusal could not rest on an incomplete appraisal of the arrest material, and the Designated Court had to reconsider the matter in light of the statutory scheme and the material placed before it. The impugned order was set aside, with compensation and action-related claims deferred to fresh consideration.

Power of arrest under Section 19 of the PMLA - Reason to believe recorded in writing - Material in possession of the authorised officer - Non-application of Section 41A Cr.P.C. to arrests under the PMLA - Judicial review of remand orders by Designated Courts - Remand for fresh consideration by the Designated Court - Initiation of action under Section 62 of the PMLA for non-compliancePower of arrest under Section 19 of the PMLA - Reason to believe recorded in writing - Material in possession of the authorised officer - Judicial review of remand orders by Designated Courts - Validity of the Designated Court's rejection of the ED's remand application dated 14.06.2023 - HELD THAT: - The High Court held that the impugned remand-rejection order dated 14.06.2023 cannot stand and is liable to be set aside. The learned Metropolitan Sessions Judge had rejected remand on two grounds: non-compliance of Section 41A Cr.P.C. and that the reasons stated for arrest were not supported by justifiable material. The High Court observed that the Designated Court did not have the benefit of the Apex Court's decision in V. Senthil Balaji (delivered after the impugned order) which categorically held that Section 41A Cr.P.C. does not apply to arrests under the PMLA. With respect to the contention that reasons for arrest lacked supporting material, the High Court recorded a dispute about what documents were filed by the ED and noted that the Designated Court did not refer to or adjudicate those factual aspects in its order. For these reasons the High Court set aside the impugned order and directed fresh consideration, indicating that the Designated Court must examine the material submitted by the ED and the recorded reasons to believe in accordance with law and established principles. The High Court emphasised that the authorised officer's discretion under Section 19 is conditioned on material in possession and reasons to believe recorded in writing, and that the Designated Court must consider such material without venturing into trial-type appreciation of evidence. [Paras 10, 11, 12]Impugned remand-rejection order dated 14.06.2023 set aside; matter remitted for fresh consideration by the Designated Court with directions to consider the remand application and the material in accordance with law.Non-application of Section 41A Cr.P.C. to arrests under the PMLA - Remand for fresh consideration by the Designated Court - Initiation of action under Section 62 of the PMLA for non-compliance - Scope of further proceedings after setting aside the remand order and the limited nature of the High Court's intervention - HELD THAT: - The High Court remanded the matter to the Designated Court for fresh adjudication of the remand application, directing the Designated Court to place the parties on notice, to afford opportunity to file and rely upon all material and contentions, and to apply the principles laid down by the Apex Court (including the decision that Section 41A does not apply to PMLA arrests). The High Court made clear that it did not decide the legality of the arrest on merits; that question is to be determined by the Designated Court on fresh consideration. The High Court also observed that any claim for compensation or action under Section 62 of the PMLA arising from alleged illegality of arrest is to be sought before the appropriate forum after the Designated Court decides the remand/legality issue. The Designated Court was directed not to insist on the physical presence of the respondents in the present revision proceedings but to require their appearance when the matter is posted for orders. [Paras 11, 12]Matter remanded to the Designated Court for fresh consideration strictly in accordance with law; respondents may pursue compensation or Section 62 proceedings thereafter.Final Conclusion: The High Court set aside the Designated Court's remand-rejection order dated 14.06.2023 and remanded the matter to the learned Metropolitan Sessions Judge/Designated Court for fresh consideration of the ED's remand application; the Designated Court is directed to consider all material and authorities (including the Apex Court's ruling on non-application of Section 41A Cr.P.C. to PMLA arrests) and to decide the legality of the arrests, after which the respondents may seek compensation or initiation of proceedings under Section 62 of the PMLA.

2023 (9) TMI 1416 - ALLAHABAD HIGH COURT Money Laundering

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Anticipatory bail denied under Money Laundering Act for non-compliance with court orders and non-bailable warrant.
The court rejected the anticipatory bail application for the applicant involved in Complaint Case no. 126 of 2023 under the Prevention of Money Laundering Act, 2002. The applicant failed to appear before the trial court despite a non-bailable warrant and a prior opportunity to apply for bail. The court determined that the applicant's conduct did not merit discretionary relief, resulting in the denial of the pre-arrest bail request.

2023 (9) TMI 238 - MADRAS HIGH COURT Money Laundering

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Issues Involved:
1. Jurisdiction of the Court to entertain the bail application.
2. Transfer of case papers to the appropriate court.
3. Compliance with Section 43(1) of the Prevention of Money Laundering Act, 2002 (PMLA Act).

Summary:

Jurisdiction of the Court to entertain the bail application:
The petitioner, a sitting MLA, was arrested and filed a bail application before the Special Court-I for the Trial of Cases relating to MPs and MLAs. The Special Court-I returned the application, stating it was not notified under Section 43 of the PMLA Act, directing it to be filed before the Principal Judge, Chennai. The Principal Judge also returned the application, directing it back to the Special Court-I. This led to the petitioner filing the present original petition.

Transfer of case papers to the appropriate court:
The Principal Judge, Chennai, had transferred the case papers to the Special Court-I for Trial of Cases against MLAs and MPs. However, the Special Court-I returned the bail application, citing lack of notification under Section 43 of the PMLA Act. The Principal Judge, Chennai, reiterated that the case records were made over to the Special Court-I, leading to confusion about the appropriate court for the bail application.

Compliance with Section 43(1) of the PMLA Act:
Section 43(1) of the PMLA Act empowers the Central Government, in consultation with the Chief Justice of the High Court, to designate Special Courts for trial of offenses under the Act. The Central Government had issued a notification on 05.02.2016 designating the Principal District Judge, Chennai, as a Special Court for such offenses. The Court noted that the transfer of the case to the Special Court-I was not in consonance with Section 43(1) of the PMLA Act and the notification.

Judgment:
The Court directed the Principal Judge, Chennai, to withdraw the made-over case from the Special Court-I and entertain the bail application. The impugned return orders by both courts were set aside. The Principal Judge was instructed to number the bail application and decide it at the earliest. The Registry was directed to return the original bail application case papers to the petitioner's counsel. The Criminal Original Petition was disposed of with these directions.

Court orders Principal Judge to reconsider MLA's bail application promptly, setting aside previous rejections.
The Court directed the Principal Judge, Chennai, to withdraw the case from the Special Court-I and entertain the bail application filed by the sitting MLA. The orders returning the application by both courts were set aside, instructing the Principal Judge to decide on the bail application promptly. The Registry was directed to return the case papers to the petitioner's counsel.

Designation of Special Courts under Section 43(1) of the PMLA Act - territorial jurisdiction of a Special Court as fixed by Central Government notification - competence of trial court to try offences punishable under Section 4 of the PMLA Act - validity of made-over/transfer of case contrary to statutory designation - entertainment and numbering of bail application by competent Special CourtDesignation of Special Courts under Section 43(1) of the PMLA Act - territorial jurisdiction of a Special Court as fixed by Central Government notification - competence of trial court to try offences punishable under Section 4 of the PMLA Act - Whether the Special Court-I established by State G.O. could exercise jurisdiction to try the offence under Section 4 of the PMLA Act when the Central Government notification had designated the Principal District Judge, Chennai as the Special Court for the territorial area. - HELD THAT: - The Court examined Section 43(1) of the PMLA Act and the Central Government notification issued in exercise of powers under that provision which specifically designated the Principal District Judge, Chennai as a Special Court for offences punishable under Section 4 within the territorial limits specified. The language of Section 43(1) makes the designation the prerogative of the Central Government in consultation with the High Court. Having regard to the notification S.O.372(E) dated 05.02.2016 and the territorial coverage it specifies (including Chennai), the Court held that cases alleging offences under Section 4 must be tried by the Courts so designated by the Central Government. The transfer/made over of C.C.No.9 of 2023 to Special Court-I constituted under the State G.O. was therefore inconsistent with the statutory designation and could not confer jurisdiction on that Special Court to try the offence charged under Section 4 of the PMLA Act. [Paras 21, 28, 29, 30, 31]The transfer/made over to Special Court-I was not in consonance with Section 43(1) and the Central Government notification; the Principal District Judge, Chennai is the competent Special Court to try the offence charged under Section 4 in the territorial area.Validity of made-over/transfer of case contrary to statutory designation - entertainment and numbering of bail application by competent Special Court - Whether the return of the bail application by both the Principal Judge and Special Court-I was correct and what relief should follow. - HELD THAT: - Having concluded that the Principal District Judge, Chennai is the specially designated Court under the Central notification for offences punishable under Section 4, the Court found that the endorsement/return by the Principal Judge and the consequent refusal by Special Court-I to entertain the bail petition were unsustainable. The appropriate remedy is to set aside the impugned return/endorsement, direct withdrawal/re-transfer of the made-over file from Special Court-I back to the Principal Judge, Chennai, and require the Principal Judge to number and entertain the unnumbered bail application if in order and decide it after hearing both sides at the earliest. Ancillary directions were given for return of original bail papers to the petitioner's counsel after retaining photocopies. [Paras 32, 33]The impugned endorsement/return is set aside; the made-over file shall be withdrawn from Special Court-I and the Principal Judge, Chennai shall number, entertain and decide the bail application after hearing both parties.Final Conclusion: The petition is allowed: the Principal Judge, Chennai being the Special Court designated by the Central Government under Section 43(1) of the PMLA Act is to hear and decide the bail application in C.C.No.9 of 2023; the return/endorsement is set aside and the made-over file shall be re-transferred to the Principal Judge who shall number and dispose of the bail petition after hearing both sides at the earliest; registry to return original bail papers to the petitioner's counsel after retaining photocopy.

2023 (9) TMI 1472 - PATNA HIGH COURT Money Laundering

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Bail in money laundering case granted after prolonged custody, delayed trial, and parity with a co-accused.
Bail under the Prevention of Money Laundering Act was granted to the accused after prolonged custody, because the trial had not reached the stage of framing charge and there was no indication of early conclusion. Parity with a similarly placed co-accused who had already been enlarged on bail also weighed in favour of release. The objection based on other criminal cases was not found sufficient on the facts to deny bail. Relief was made subject to conditions requiring cooperation in trial, regular appearance, non-tampering with evidence, and verification of criminal antecedents.

Grant of regular bail in PMLA proceedings - Custodial detention and delay in trial - Comparative parity where co-accused released on bail - Verification of criminal antecedents as bail condition - Tampering with evidence as ground for cancellation of bailGrant of regular bail in PMLA proceedings - Custodial detention and delay in trial - Comparative parity where co-accused released on bail - Verification of criminal antecedents as bail condition - Tampering with evidence as ground for cancellation of bail - Petitioner released on bail in Special Trial No.(PMLA) 04 of 2018 subject to conditions - HELD THAT: - The petitioner, in custody since 11.12.2020 in connection with proceedings under the Prevention of Money Laundering Act, was held entitled to be released on bail. The court took into account the prolonged pre-trial custody and the Trial Court's report dated 09.08.2023 that charges have not yet been framed, indicating no immediate prospect of an early conclusion of trial. The court also noted that a similarly situated co-accused had been granted bail by a Coordinate Bench and, notwithstanding the Union of India's opposition based on the petitioner's other criminal cases, directed conditional release. Conditions were imposed to secure attendance and the integrity of the process: furnishing of bail bond and sureties, cooperation and presence at trial dates (with cancellation on two consecutive unexplained absences), liberty to move for cancellation of bail if the petitioner tampers with evidence or witnesses, and verification of the petitioner's criminal antecedents by the court below (with bail acceptance not to be delayed on that account).Petitioner released on bail on furnishing bond of Rs. 10,000 with two like sureties to the satisfaction of the learned Sessions Judge/Special Judge, Patna, subject to conditions of cooperation, attendance, prohibition on tampering with evidence, and verification of antecedents; prosecution may move for cancellation of bail if conditions are violated.Final Conclusion: Bail granted to the petitioner in the PMLA matter on the stated bond and conditions owing to extended pre-trial custody, absence of immediate trial conclusion, and parity with co-accused who had been released; court retained power to cancel bail on specified grounds.

2023 (9) TMI 1452 - DELHI HIGH COURT Money Laundering

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Medical treatment and custody balance led to limited relief for continued follow-up care and rehabilitation.
The Delhi High Court considered whether an earlier custody order should be modified to allow continued medical treatment and follow-up care at the requested hospital while preserving custody arrangements. The Court noted that the discharge summary required post-operative review, stitch removal, rehabilitation and supervised follow-up treatment, and recognised the need for effective medical care while the presumption of innocence remains until guilt is established. Balancing these considerations against the seriousness of the allegations, the Court declined the request in the exact terms sought but granted limited relief by directing custody transfer, OPD follow-up, rehabilitation, examination by the medical board, and compliance with the discharge advice.

Right to effective medical treatment of an undertrial - custody of Superintendent Jail for hospitalisation and medical escort - continuation of post operative follow up and rehabilitation as per discharge advice - medical board examination and furnishing of report to the Court - obligation of the undertrial to bear expenses of OPD and rehabilitation visits - presumption of innocence and its bearing on entitlement to medical careRight to effective medical treatment of an undertrial - presumption of innocence and its bearing on entitlement to medical care - custody of Superintendent Jail for hospitalisation and medical escort - Modification of earlier order to permit the petitioner to receive medical treatment at VNA Hospital and arrangements for custody/transport by the Superintendent Jail. - HELD THAT: - The Court accepted that the petitioner, who is an undertrial and is presumed innocent, is entitled to effective and proper medical treatment. Considering the discharge summary and ongoing post operative requirements, the Court modified its earlier direction to permit treatment at VNA Hospital under the care of the treating surgeon. The Superintendent Jail was directed to take custody of the petitioner from VNA Hospital today before 8 p.m. in a proper ambulance with a doctor and necessary medical facilities to ensure safe transport and hospital custody. [Paras 8, 9]Petitioner permitted to take medical treatment at VNA Hospital and Superintendent Jail to take custody and provide medically equipped transport and escort.Continuation of post operative follow up and rehabilitation as per discharge advice - custody of Superintendent Jail for hospitalisation and medical escort - Directions to follow the BLK Max discharge advice, including OPD visits for stitch removal, follow up with Operating Spine Surgeon, and twice weekly rehabilitation sessions. - HELD THAT: - On perusal of the BLK Max discharge summary and follow up advice, the Court directed that the petitioner shall be taken as required to VNA Hospital as an OPD patient for stitch removal and to the Operating Spine Surgeon for postoperative review. The Superintendent Jail must strictly follow the medical advice in the discharge summary and ensure the petitioner attends supervised rehabilitation sessions twice weekly at the Centre for Sports Rehabilitation for gait training and strengthening on specified equipment. [Paras 7, 9]Petitioner to receive post operative follow up and rehabilitation in accordance with the BLK Max discharge advice, with jail authorities ensuring attendance.Medical board examination and furnishing of report to the Court - Direction for medical board examination and transmission of its report. - HELD THAT: - In continuation of earlier directions, the Court ordered that, after constitution of the medical board, the petitioner be medically examined by the medical board within two weeks. The Medical Superintendent of AIIMS is directed to send a copy of the medical board report to the Court, and copies are to be supplied to the petitioner, Enforcement Directorate and CBI, with concerned investigating officers coordinating with the office of the Medical Superintendent. [Paras 11]Medical board to examine the petitioner within two weeks and the Medical Superintendent, AIIMS to file and supply the report as directed.Obligation of the undertrial to bear expenses of OPD and rehabilitation visits - Petitioner's liability to bear expenses for OPD follow ups and rehabilitation sessions at VNA Hospital. - HELD THAT: - The Court directed that the petitioner shall bear all expenses related to his OPD visits at VNA Hospital for follow up with the Operating Spine Surgeon and for rehabilitation sessions twice weekly at the Centre for Sports Rehabilitation. This obligation was made a condition of permitting treatment and follow up outside the original hospital. [Paras 10]Petitioner ordered to bear the expenses of OPD follow ups and rehabilitation sessions at VNA Hospital.Final Conclusion: Application under Section 482 Cr.P.C. was allowed to the limited extent of permitting the petitioner to continue postoperative treatment and rehabilitation at VNA Hospital under his treating surgeon, with custody, safe transport and medical escort by the Superintendent Jail, strict adherence to the BLK Max discharge advice, petitioner bearing OPD and rehabilitation expenses, and a medical board examination to be conducted within two weeks with its report furnished to the Court.

2023 (9) TMI 1462 - ORISSA HIGH COURT Money Laundering

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Section 482 CrPC cannot quash an ECIR under PMLA before complaint filing; pre-complaint challenge is premature.
Section 482 CrPC is confined to criminal proceedings under the Code and cannot be used to quash an ECIR, which is only an internal administrative step under the Prevention of Money-Laundering Act. As the ECIR is not equivalent to an FIR and prosecution under the Act begins only on filing of a complaint under Section 44, judicial review at the pre-complaint stage was premature. The petition was held not maintainable and the challenge rejected.

Inherent power under Section 482 Cr.P.C. - ECIR as an internal/administrative document vis-a -vis FIR - Special procedure under the Prevention of Money Laundering Act - Maintainability of Section 482 challenge to ECIR/ongoing PML investigation - Prematurity of judicial review prior to filing of complaint under Section 44 of PML ActInherent power under Section 482 Cr.P.C. - ECIR as an internal/administrative document vis-a -vis FIR - Special procedure under the Prevention of Money Laundering Act - Prematurity of judicial review prior to filing of complaint under Section 44 of PML Act - Whether registration of an ECIR and the investigation purportedly emanating therefrom are amenable to quashing under the High Court's inherent jurisdiction under Section 482 Cr.P.C. - HELD THAT: - The Court held that Section 482 Cr.P.C. can be exercised only in relation to criminal proceedings under the Code or to prevent abuse of the process of a court. The Prevention of Money Laundering Act, 2002 (PML Act) prescribes a special, sui generis procedure for inquiry/investigation and for prosecution by way of complaint under Section 44; the scheme does not contemplate registration of an ECIR as equivalent to registration of an FIR under Section 154 Cr.P.C. Reliance on the Supreme Court's analysis in Vijay Madanlal Choudhary establishes that ECIR is an internal/administrative document created by the Enforcement Directorate to initiate inquiry/investigation and is not a statutory or prosecutorial act akin to lodging a complaint under the PML Act. Consequently, registration of an ECIR and preliminary investigative steps short of filing a complaint before the Special Court do not amount to a criminal proceeding under the Cr.P.C. that is subject to quashing by the High Court under Section 482. For these reasons, judicial review by exercise of inherent jurisdiction at the ECIR/initial inquiry stage is premature; any challenge to penal proceedings under the PML Act must await lodging of a formal complaint under Section 44 or other justiciable action by a criminal court. [Paras 9, 12]Registration of the ECIR and the ongoing investigation/enquiry therefrom are not amenable to judicial review under Section 482 Cr.P.C.; the petition is premature and dismissed as not maintainable.Final Conclusion: The petition under Section 482 Cr.P.C. challenging registration of the ECIR and consequent investigation is dismissed as not maintainable because an ECIR is an administrative document under the PML Act and judicial intervention under Section 482 is premature until prosecutorial action by way of complaint under Section 44 is initiated.

2023 (9) TMI 1450 - DELHI HIGH COURT Money Laundering

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Court Denies Further Bail Extension for Surgery; Orders Hospitalization with Strict Conditions.
The petitioner requested a three-month extension of interim bail due to a knee injury requiring surgery, following previous extensions. The ED opposed the request, citing concerns over prolonged bail. The HC denied further extension, ordering hospitalization until discharge with restricted phone use and visitation. AIIMS was tasked with verifying medical documents, allowing the petitioner to seek bail extension based on AIIMS' medical opinion. This decision underscores the balance between the right to medical treatment and preventing misuse of interim bail extensions.

Interim bail on medical grounds - right to medical treatment of accused - custodial hospitalization - verification by medical board - temporary custody in hospitalInterim bail on medical grounds - right to medical treatment of accused - Extension of interim bail granted earlier on medical grounds was not allowed to be further extended. - HELD THAT: - The Court acknowledged the fundamental right of an accused to proper and effective medical treatment and accepted that the petitioner suffers from continuing back and knee problems requiring post-operative care. Notwithstanding this, the Court emphasised that repeated and open ended extensions of interim bail on medical grounds risk creating a precedent amenable to misuse. Balancing the accused's medical needs against the risk of indefinite concessions, the Court declined to further extend interim bail but provided a limited, structured alternative to ensure medical care while preserving custodial control. [Paras 8]Interim bail not extended; further extension refused while medical needs to be met under custodial supervision.Custodial hospitalization - temporary custody in hospital - verification by medical board - Petitioner permitted to remain hospitalized in a specified hospital in the custody of the Superintendent Jail for a limited period and the medical records were directed to be verified by a constituted medical board at AIIMS. - HELD THAT: - As a tailored measure, the Court directed that the petitioner remain hospitalised at BLK Max Super Speciality Hospital under the custody of the Superintendent Jail until discharge, subject to a maximum period of two weeks except on further medical advice. Family visits were permitted under supervision with restrictions on phones; home cooked meals were allowed. Separately, the Court directed the Medical Superintendent, AIIMS, to constitute a medical board to examine the records and furnish a definite opinion on whether the petitioner's condition requires hospitalization in a particular hospital or could be managed in jail or a referral hospital. The petitioner was afforded liberty to seek further extension before the trial court in light of AIIMS' opinion. [Paras 8, 9, 10]Petitioner to remain hospitalised in custody for up to two weeks; AIIMS medical board to verify records and opine; liberty to approach trial court after AIIMS opinion.Final Conclusion: The petition for further extension of interim bail on medical grounds was refused; instead the Court ordered custodial hospitalization at a specified hospital for a limited period with supervised family access, directed verification of medical records by an AIIMS medical board, and permitted the petitioner to move the trial court for any further relief in light of the AIIMS opinion.

2023 (8) TMI 1464 - DELHI HIGH COURT Money Laundering

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PMLA bail granted on prima facie assessment where material did not show likely reoffending or justify continued detention.
At the PMLA bail stage, the Delhi HC applied the twin conditions on a prima facie, broad-probabilities basis rather than by meticulous evidence assessment. It held that the court must consider whether there are reasonable grounds to believe the accused is not guilty and whether release is likely to lead to reoffending, but need not record a positive finding of innocence. On the material, the alleged role was limited to assisting the main accused and handling or routing funds, while no material showed personal gain or a likelihood of repeating the offence. Bail was granted, with mens rea left for trial.

Bail under the Prevention of Money Laundering Act (PMLA) - twin conditions for bail under Section 45 PMLA - prima facie satisfaction on mens rea and guilt - broad probabilities standard at the bail stage - risk of tampering with witnesses and hampering investigation - parity in grant of bail focusing on the role of the accused - constitutional protection of personal liberty and effects of prolonged incarcerationBail under the Prevention of Money Laundering Act (PMLA) - twin conditions for bail under Section 45 PMLA - prima facie satisfaction on mens rea and guilt - broad probabilities standard at the bail stage - risk of tampering with witnesses and hampering investigation - Admission of the petitioner to bail in proceedings under the PMLA - HELD THAT: - The Court applied the established principle that while considering bail under PMLA the court must examine material on record on the basis of broad probabilities and reach a prima facie view as to whether the accused may be guilty and whether there is a likelihood of committing an offence on release. The Court noted binding precedents requiring that the stage of bail is not for meticulous appreciation of evidence but for a reasonable prima facie assessment of mens rea and the possibility of hindrance to investigation. Applying these principles to the facts, the Court observed that the petitioner is a young woman employed as a salon manager, there is no material that she used proceeds for personal benefit, and the allegations about rewards and purchases require testing on evidence, particularly mens rea. The Court also found no material to indicate a real risk that the petitioner would commit a like offence if enlarged on bail. Balancing the gravity of the allegations against the need to protect personal liberty and absent persuasive evidence of flight risk or likelihood of tampering, the Court held that the petitioner should be admitted to bail subject to stringent conditions to secure attendance and prevent interference with investigation. The Court recorded that its order is based on prima facie appraisal and does not express any view on merits of the case. [Paras 26, 27, 28, 29, 30]Petitioner admitted to bail on furnishing bond and surety and subject to conditions including surrender of passport, residence and communication obligations, non-contact with co-accused/witnesses, and prohibition on committing further offences.Final Conclusion: The High Court allowed the petition for bail under Section 45 PMLA r/w Section 439 CrPC, granting interim liberty to the petitioner on execution of bonds and specified conditions while recording that the order is a prima facie view and does not decide the merits.

2023 (8) TMI 1241 - ALLAHABAD HIGH COURT Money Laundering

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PMLA bail granted on weak prima facie material, prolonged custody, completed investigation and parity with a co-accused.
In a PMLA prosecution, bail was granted because the material did not prima facie establish that the applicant had planned the alleged laundering activity or that the disputed funds were clearly proceeds of crime. The Court treated the share-allotment and property-transaction allegations as matters that, by themselves, did not necessarily amount to an offence under the scheduled law so as to attract the money-laundering charge. It also relied on the applicant's substantial custody, completion of investigation, the likelihood of a prolonged trial, absence of concrete material showing a real risk of reoffending, and parity with a co-accused already on bail, and held that release was justified.

Prima facie satisfaction on broad probabilities - proceeds of crime - statutory bail threshold under Section 45 of the PMLA - reverse burden of proof - parity in grant of bail - custodial necessity and delay in taking accused into custodyPrima facie satisfaction on broad probabilities - statutory bail threshold under Section 45 of the PMLA - reverse burden of proof - proceeds of crime - Entitlement of the applicant to bail in proceedings under the PMLA - HELD THAT: - Applying the test of broad probabilities as explained in Rohit Tandon, the Court examined whether there is a prima facie case on the material placed by the Enforcement Directorate and whether the property seized can be regarded as "proceeds of crime" within the strict meaning in Vijay Madanlal Choudhary. The Court noted that the applicant was not named in the initial FIRs or ECIR, his statements under Section 50 PMLA were recorded long before his arrest, and there is nothing on record prima facie to show he planned the Bikebot scheme. The ED's allegations regarding transfers to Mars Envirotech and alleged flawed allotment of CCCPS were in dispute and, applying Vijay Madanlal Choudhary, the Court observed that irregularities in share transfers do not ipso facto convert funds or property into proceeds of crime absent a scheduled offence. The Court also applied the principle that reverse burden provisions under the PMLA do not dispense with the need for the prosecution to establish a prima facie case before the burden shifts, and that any iota of doubt must be resolved in favour of the accused. Considering custodial delay, completion of investigation long before arrest, likelihood of protracted trial, absence of material to show a reasonable apprehension of the accused fleeing or tampering with evidence, and that co-accused in similar roles have been granted bail, the Court concluded that the statutory threshold for denial of bail under Section 45 was not made out on the material before it. [Paras 43, 46, 49, 50, 51]Applicant entitled to be released on bail in the PMLA proceedings subject to furnishing bond and sureties and specified conditions (non-tampering, non-pressurising witnesses, attendance, surrender of passport).Final Conclusion: Bail application allowed; applicant Badri Narayan Tiwari directed to be released on bail in the Session Case arising out of ECIR/LKZO/05/2019 on furnishing bond and two sureties subject to enumerated conditions, and prosecution may move for cancellation of bail in case of breach.

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