Prima facie case at charge stage bars detailed evidence review; PMLA charges upheld despite valuation dispute.

At the discharge or charge-framing stage under the Prevention of Money Laundering Act, the court must only see whether the prosecution material discloses a prima facie case and sufficient grounds to proceed; it cannot weigh evidence as at trial. A plea that seized articles were undervalued and below the statutory threshold involved a disputed question of fact and did not by itself show the charge was groundless. Because the allegations also concerned parking proceeds of crime in bank accounts and using those proceeds to purchase properties, the court found no abuse of process and upheld the framing of charges, rejecting the challenge to discharge.

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Issues: Whether the applicants were entitled to discharge and quashing of the charge under the Prevention of Money Laundering Act, 2002 on the ground that the alleged seized articles were not properly valued and that no prima facie case existed against them.

Analysis: At the stage of discharge or framing of charge, the court is required to examine only whether the material collected by the prosecution discloses a prima facie case and sufficient grounds to proceed. The court cannot undertake a meticulous appraisal of evidence or determine its probative value as if conducting a trial. The plea that the seized articles were not properly valued and that their market value was below the statutory threshold raised a disputed question of fact. The allegations were not confined to the seized articles alone, but also included parking of proceeds of crime in bank accounts and use of such proceeds for purchase of properties. On these materials, the court found no basis to hold that the charge was groundless or that the proceedings amounted to an abuse of process.

Conclusion: The challenge to the rejection of discharge failed, and the framing of charges was held to be justified.

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