Disclosure of PMLA investigation statements cannot be compelled during an ongoing probe; supply may follow completion of investigation.

During a crucial stage of an ongoing PMLA investigation, the Delhi HC held that a person cannot compel disclosure of a statement recorded under Section 50 on natural justice grounds, because an accused has no right to direct the manner or timing of investigation. The Court noted that investigative statements are ordinarily not supplied during investigation and are instead furnished after completion, as with Section 161 CrPC material. It accepted that the requested statement would be provided after the investigation concluded, and upheld the refusal to disclose it at the initial stage.

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Issues: Whether the petitioner was entitled to a copy of the statement recorded under Section 50(2) of the Prevention of Money Laundering Act, 2002 during the pendency of investigation.

Analysis: The statement sought was part of an investigation that was at a crucial stage. The Court held that principles of natural justice cannot be invoked to require disclosure at that stage, because an accused has no right to dictate the manner and method of investigation. It also noted that statements recorded during investigation under Section 161 of the Code of Criminal Procedure, 1973 are ordinarily not supplied during investigation and are furnished along with the charge-sheet. The Court accepted that the petitioner's statement under Section 50 of the Prevention of Money Laundering Act, 2002 would be supplied after completion of investigation.

Conclusion: The refusal to supply the statement at the initial stage was justified and the challenge to the impugned order failed.

Ratio Decidendi: During an ongoing and crucial investigation, disclosure of statements recorded under Section 50 of the Prevention of Money Laundering Act, 2002 cannot be compelled on natural justice grounds; such material may be supplied after completion of investigation.

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