Prima facie material is required for PMLA summons; mere fund transfers or association do not establish money laundering involvement.

An order taking cognizance and issuing summons is not interlocutory and can be challenged in revision. In proceedings under the Prevention of Money Laundering Act, 2002, the Court held that mere banking transactions, receipt of funds through accounts, or association with the main accused do not by themselves establish the knowledge or active involvement needed for money laundering. The materials before the Special Court did not disclose a prima facie case of knowing participation in a process connected with proceeds of crime and projection of tainted property as untainted, so the summons order was set aside.

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Issues: (i) whether the revision petition was maintainable against the order taking cognizance and issuing summons; and (ii) whether the Special Court's order taking cognizance and issuing summons under the Prevention of Money Laundering Act, 2002 was sustainable for want of prima facie material showing the applicants' involvement in money laundering.

Issue (i): whether the revision petition was maintainable against the order taking cognizance and issuing summons.

Analysis: An order directing issuance of summons on taking cognizance is not interlocutory in nature. It is open to challenge in revisional jurisdiction, and the Court may also examine whether the process was issued mechanically without application of mind and without a prima facie case. The maintainability objection was therefore not accepted.

Conclusion: The revision petition was maintainable.

Issue (ii): whether the Special Court's order taking cognizance and issuing summons under the Prevention of Money Laundering Act, 2002 was sustainable for want of prima facie material showing the applicants' involvement in money laundering.

Analysis: Offence of money laundering under Section 3 requires involvement in any process or activity connected with proceeds of crime, coupled with concealment, possession, acquisition, use, or projection/claim of such property as untainted. Mere banking transactions, receipt of funds through accounts, or relationship with the main accused did not by themselves establish the requisite knowledge, mens rea, or active involvement. The material before the Special Court did not disclose any prima facie case that the applicants knowingly assisted, were party to, or were actually involved in laundering proceeds of crime. The order was held to have been passed mechanically.

Conclusion: The order taking cognizance and issuing summons was unsustainable and was set aside.

Final Conclusion: The applicants were entitled to relief, and the proceedings against them could not continue on the material then available.

Ratio Decidendi: For prosecution under Section 3 of the Prevention of Money Laundering Act, 2002, the Court must find prima facie material showing knowing involvement in a process connected with proceeds of crime and projection of such property as untainted; absent such material, an order issuing summons is liable to be quashed in revision.

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