PMLA summons validity upheld where later inclusion of the scheduled offence did not defeat investigation or appearance.

Summons issued under the Prevention of Money Laundering Act were upheld as valid because they were issued under the statutory power in Section 50(2) and Section 50(3), and Section 68 saves proceedings from invalidity for mistake, defect or omission when they are substantially in conformity with the Act. The challenge that Section 420 IPC had been added to the scheduled offences only later was rejected as unsustainable, and the court found no basis to resist appearance in the investigation. The process under Section 50 was also held not to infringe Article 20(3) of the Constitution. The summons was therefore treated as within jurisdiction.

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Issues: Whether the summons issued under the Prevention of Money Laundering Act, 2002 was jurisdiction or otherwise invalid on the ground that Section 420 of the Indian Penal Code had been brought within the scheduled offences only later, and whether the petitioner could resist appearance in the investigation.

Analysis: The summons was issued in exercise of the power under Section 50(2) and Section 50(3) of the Prevention of Money Laundering Act, 2002. Section 68 of the Act protects notices, summonses and other proceedings from invalidity merely because of mistake, defect or omission, so long as they are in substance and effect in conformity with the Act. The object of the Act is to prevent money laundering and to facilitate investigation into the offence and connected property, and the Court held that the challenge based on the timing of the scheduled offence was unsustainable. The Court also noted that the process under Section 50 does not violate Article 20(3) of the Constitution of India.

Conclusion: The summons was held to be valid and within jurisdiction. The challenge failed.

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