PMLA discharge and charge framing require only prima facie material; revision cannot become a mini trial on the defence.

At the discharge and charge-framing stage in a PMLA prosecution, the court considers only whether the prosecution material discloses sufficient grounds and a prima facie case; it cannot conduct a mini trial, weigh the defence on merits, or reappreciate evidence in revision. Revisional interference lies only for patent illegality, jurisdictional defect, or a groundless charge. Applying that standard, the High Court found no perversity in the orders rejecting discharge and framing charge, and held that witness statements, documents, suspicious share transfers, and company structures showed enough material to proceed. The absence of the petitioners' names in the predicate offence was not conclusive, as money-laundering is an independent and continuing offence.

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Issues: (i) Whether the orders rejecting discharge and framing charge in the money-laundering prosecution suffered from legal error warranting interference in revision. (ii) Whether the record disclosed a prima facie case against the petitioners and their companies for offence under the Prevention of Money Laundering Act, 2002.

Issue (i): Whether the orders rejecting discharge and framing charge in the money-laundering prosecution suffered from legal error warranting interference in revision.

Analysis: The scope of discharge and framing of charge is confined to seeing whether the materials produced by the prosecution disclose sufficient grounds for proceeding. At that stage the court may sift the materials, but it cannot conduct a mini trial, weigh the defence case on merits, or undertake a meticulous appreciation of evidence. Revisional interference is justified only where there is a patent legal error, jurisdictional defect, or a case where the charge is groundless on the face of the record.

Conclusion: The orders did not suffer from such illegality or perversity as would justify revisional interference.

Issue (ii): Whether the record disclosed a prima facie case against the petitioners and their companies for offence under the Prevention of Money Laundering Act, 2002.

Analysis: The materials relied upon by the prosecution, including witness statements, documentary records, alleged nexus with co-accused persons, transfer and sale of shares at suspicious values, and use of company structures, were held sufficient to show involvement in the process or activity connected with proceeds of crime. The offence of money-laundering was treated as an independent and continuing offence, and the absence of the petitioners' names in the predicate offence was not considered conclusive where the materials otherwise suggested knowing assistance in concealment, possession, acquisition, use, and projection of proceeds of crime as untainted property. The supplementary complaint was also found maintainable.

Conclusion: A prima facie case was made out against the petitioners and their companies.

Final Conclusion: The revisional challenge failed, and the prosecution was permitted to proceed on the basis of the existing materials.

Ratio Decidendi: At the stage of discharge or framing of charge in a prosecution under the Prevention of Money Laundering Act, 2002, the court must determine only whether the prosecution material discloses a prima facie case and grave suspicion, without entering into a mini trial or evaluating the defence on merits; revisional interference is warranted only on patent illegality or absence of sufficient material.

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