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Issues: Whether the Central Bureau of Investigation could investigate the scheduled offences when the Prevention of Money Laundering Act, 2002 separately confers jurisdiction on the Enforcement Directorate in relation to money-laundering, and whether the direction to continue investigation by the Central Bureau of Investigation called for interference.
Analysis: The scheme of the Prevention of Money Laundering Act, 2002 was examined to distinguish between investigation of scheduled offences and investigation of the offence of money-laundering. The Act treats money-laundering as a distinct and stand-alone offence, while the Enforcement Directorate's role under the Act is confined to that offence and the connected statutory powers regarding attachment, adjudication, and prosecution. Nothing in Sections 43, 44, or 45 of the Act was found to exclude the ordinary power of an appropriate investigating agency to investigate the underlying IPC and Prevention of Corruption Act offences. The Court also noted that the material before the High Court disclosed allegations of abuse of official position and illegal acquisition of assets, which justified investigation by the Central Bureau of Investigation, while any material relating to money-laundering could be dealt with by the Enforcement Directorate in accordance with law.
Conclusion: The Central Bureau of Investigation was competent to investigate the scheduled offences, and the challenge to the direction for such investigation was rejected.
Final Conclusion: The appeal failed, and the order directing investigation by the Central Bureau of Investigation was left undisturbed.
Ratio Decidendi: The Prevention of Money Laundering Act, 2002 does not confer exclusive investigative jurisdiction on the Enforcement Directorate over the scheduled offences; its exclusive domain is the offence of money-laundering, while investigation of the underlying offences may be carried out by the competent criminal investigating agency.