ECIR not amenable to quashing under inherent criminal jurisdiction because it is an internal administrative document.

An ECIR under the Prevention of Money Laundering Act, 2002 is treated as an internal administrative document prepared by the Enforcement Directorate before formal proceedings, not as a statutory FIR or a criminal proceeding under the Code of Criminal Procedure, 1973. Because Section 482 CrPC applies to criminal proceedings and court process, the ECIR was held outside its scope and not capable of being quashed under inherent jurisdiction. The text also notes that discharge in the predicate offences did not alter the character of the ECIR or make the challenge maintainable under Section 482 CrPC.

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Issues: Whether an ECIR, being an internal administrative document under the Prevention of Money Laundering Act, 2002, can be quashed in the exercise of inherent jurisdiction under Section 482 of the Code of Criminal Procedure, 1973.

Analysis: The petition challenged the ECIR on the basis of discharge in the predicate offences and sought quashing under Section 482 of the Code of Criminal Procedure, 1973. The relevant legal framework was examined in light of the nature of an ECIR under the Prevention of Money Laundering Act, 2002 and the distinction between an ECIR and an FIR. The Court accepted the position that an ECIR is not a statutory document under the Code of Criminal Procedure, 1973, does not stand on the same footing as an FIR, and is an internal administrative document prepared by the Enforcement Directorate before initiation of proceedings under the special statute. Since Section 482 of the Code of Criminal Procedure, 1973 operates in relation to criminal proceedings and court process, the ECIR, being outside that framework, was held not amenable to quashing under that provision.

Conclusion: The petition was held to be not maintainable under Section 482 of the Code of Criminal Procedure, 1973 for quashing the ECIR and the challenge failed on that ground.

Ratio Decidendi: An ECIR under the Prevention of Money Laundering Act, 2002 is an internal administrative document and not the equivalent of an FIR or a criminal proceeding under the Code of Criminal Procedure, 1973, so it cannot be quashed in exercise of inherent jurisdiction under Section 482.

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