Separate money-laundering transactions cannot be clubbed in one complaint when each alleged act forms an independent offence.

Where different land-acquisition transactions generated distinct proceeds of crime, each alleged act of money laundering was treated as a separate offence under the Prevention of Money Laundering Act, 2002. The Court held that clubbing such distinct laundering episodes into one complaint was inconsistent with the principle that separate offences and different offenders cannot be joined in a manner that offends the rules on joinder of charges. Because the consolidated complaint would complicate trial and was not maintainable in its clubbed form, it was returned for filing fresh, separate complaints for each distinct transaction.

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Issues: Whether multiple alleged acts of money laundering arising from different transactions and different proceeds of crime could be clubbed in one complaint, and whether such joinder would justify return of the complaint for filing separate complaints.

Analysis: The complaint alleged that different land-acquisition transactions gave rise to separate proceeds of crime and that each alleged laundering episode constituted an independent offence under the Prevention of Money Laundering Act, 2002. On that basis, the Court held that clubbing all such transactions in one complaint would amount to joining different offenders and distinct offences in a manner inconsistent with the principle that each act of money laundering is a separate offence. The Court further held that such clubbing would run contrary to the rules governing joinder of charges and would complicate the trial.

Conclusion: The complaint in its present clubbed form was not maintainable and was returned to the complainant for filing fresh and separate complaints in accordance with law.

Final Conclusion: The Court declined to proceed on a consolidated complaint and required separate proceedings for distinct alleged laundering transactions.

Ratio Decidendi: Where different alleged transactions generate distinct proceeds of crime, each alleged act of money laundering is a separate offence and cannot be impermissibly clubbed into one complaint in a manner that offends the rules of joinder of charges.

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