Quashing of PMLA complaint refused where complaint materials showed a prima facie nexus and disputed facts required trial.

A complaint under the Prevention of Money Laundering Act was not quashed under Section 482 CrPC because the complaint materials, including statements recorded under Section 50 PMLA, disclosed a prima facie nexus between the petitioners and the company and possible handling of proceeds of crime. Questions about source of funds, ownership of properties, and the extent of involvement were treated as disputed issues unsuitable for summary determination in inherent jurisdiction. The matter did not satisfy the recognised exceptions for quashing under the Bhajan Lal principles, and the complaint was allowed to proceed to trial.

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Issues: Whether the complaint under the Prevention of Money Laundering Act, 2002 could be quashed in exercise of inherent powers under Section 482 of the Code of Criminal Procedure, 1973 on the ground that the petitioners were not shown to be in charge of the company and that the allegations did not disclose a prima facie case of money laundering.

Analysis: The challenge was tested on the settled limits governing quashing of criminal proceedings. The material in the complaint, including the statements recorded under Section 50 of the Prevention of Money Laundering Act, 2002, disclosed a prima facie nexus between the petitioners and the first accused company, and also indicated possible involvement in handling proceeds of crime. The Court held that disputed questions about the source of funds, ownership of properties, and the extent of involvement could not be finally adjudicated in a petition under Section 482 of the Code of Criminal Procedure, 1973. The case did not fall within the recognised exceptions for quashing laid down in the Bhajan Lal principles.

Conclusion: The prayer for quashing was rejected because the complaint disclosed a prima facie case requiring trial.

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