Prima facie money laundering trail and statutory presumption can defeat discharge despite denial of knowledge at threshold.

Under the Prevention of Money Laundering Act, 2002, proceeds of crime include property derived directly or indirectly from a scheduled offence, and money laundering covers not only direct involvement but also knowing assistance, possession, acquisition, use, or projection of such proceeds as untainted property. Where the record shows a prima facie monetary trail from the scheduled offence into property connected with the accused, and the accused is linked to the laundering chain, the statutory presumption may apply at the threshold. A bare denial of knowledge or challenge to the source of funds is a matter for trial, not discharge.

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Issues: Whether the petitioner was entitled to discharge in a prosecution under the Prevention of Money Laundering Act, 2002 on the ground that no prima facie case was made out against her.

Analysis: The allegation was that money generated from the scheduled offence had travelled through the husband's account and was used, at least in part, for acquiring property in the joint names of the petitioner and her husband. On the statutory scheme of sections 2(u), 3 and 24 of the Prevention of Money Laundering Act, 2002, proceeds of crime include property derived directly or indirectly from criminal activity relating to a scheduled offence, and offence of money laundering covers not only direct participation but also knowing assistance, possession, acquisition, use, or projection of such proceeds as untainted property. The material on record, including the monetary trail and the petitioner's connection as a shareholder in the company linked to the alleged laundering, was sufficient at the threshold to show a prima facie case. The petitioner's denial of knowledge and her defence on source of funds were matters for trial, particularly in view of the statutory presumption.

Conclusion: A prima facie case existed against the petitioner, and she was not entitled to discharge.

Final Conclusion: The revisional challenge failed, and the rejection of discharge was sustained.

Ratio Decidendi: Where the material shows a prima facie monetary trail of proceeds of crime into property connected with the accused, and the statutory presumption under the Prevention of Money Laundering Act, 2002 is attracted, discharge cannot be granted merely on a denial of knowledge at the threshold.

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