Prima facie case at charge stage bars defence material from securing discharge in money-laundering proceedings.

At the discharge and charge-framing stage under the Prevention of Money Laundering Act, the court examines only whether the prosecution material, taken at face value, discloses a prima facie case or grave suspicion; it does not weigh defence material or conduct a mini-trial. The prosecution allegations of laundering through properties held in relatives' names, a trust used for fake deposits, and front companies for sham share transactions and cash movements were found sufficient to justify trial. The petitioner's explanations on income, trust assets, and third-party ownership could not be used to secure discharge. The refusal to discharge and the order framing charge were therefore upheld.

---

---

Issues: Whether the order refusing discharge and the subsequent order framing charge under the Prevention of Money Laundering Act, 2002 suffered from illegality warranting interference in revision; whether, at the stage of discharge or framing of charge, the accused could rely on defence material to seek discharge.

Analysis: The available material disclosed specific allegations that the petitioner had laundered proceeds of crime by acquiring properties in the names of relatives, routing funds through a trust allegedly used for fake deposits, and using front companies for sham share transactions and cash movements. The settled rule at the stage of framing charge is that the court examines whether the prosecution material, taken at face value, raises a prima facie case or grave suspicion; it cannot weigh defence material or conduct a mini-trial. The Court found that the defence version, including explanations regarding income, trust assets, and third-party ownership, could not be relied upon to seek discharge at that stage. The authorities cited by the petitioner were held to be distinguishable on facts and on the applicable statutory setting.

Conclusion: The refusal to discharge and the order framing charge were upheld, and no interference was warranted.

Final Conclusion: The revision failed because the prosecution material was sufficient to justify trial on the money-laundering , and the petitioner could not invoke defence evidence to secure discharge at the charging stage.

Ratio Decidendi: At the stage of discharge or framing of charge, the court must test only whether the prosecution material discloses a prima facie case or grave suspicion, and it cannot rely on the accused's defence material or undertake a roving enquiry into the merits.

---