Territorial jurisdiction and concurrent prosecution principles sustain PMLA action despite closure of one FIR and other statutory arguments.

Territorial jurisdiction was upheld because part of the cause of action arose where the petitioners carried on business and where search and seizure occurred, so the ECIR's registration elsewhere did not oust jurisdiction. Continuation of PMLA proceedings was not barred by closure of one predicate FIR, as other FIRs and continuing material involving scheduled offences remained available. The Banning of Unregulated Deposits Schemes Act, 2019 was found to operate in addition to other laws, so it did not exclude IPC prosecution or PMLA action. Alleged non-repayment, interim protection, and an SFIO investigation did not establish grounds to quash the proceedings.

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Issues: (i) Whether the Court had territorial jurisdiction to entertain the petition; (ii) whether continuation of proceedings under the Prevention of Money Laundering Act, 2002 was barred after the closure report in the predicate FIR and in view of the petitioners' reliance on other pending or connected proceedings; (iii) whether the alleged conduct could be pursued only under the Banning of Unregulated Deposits Schemes Act, 2019 and not under the Indian Penal Code or the Prevention of Money Laundering Act, 2002; (iv) whether the alleged lack of repayment, the interim protection order, and the SFIO investigation barred continuation of the impugned proceedings.

Issue (i): Whether the Court had territorial jurisdiction to entertain the petition.

Analysis: The petitioners carried on business from Lucknow and the search and seizure operations were conducted at their premises there. A part of the cause of action therefore arose within the territorial jurisdiction of the Court. The objection that the ECIR was registered at Kolkata did not, by itself, oust jurisdiction where material events also occurred at Lucknow.

Conclusion: The territorial objection was rejected and the petition was held maintainable before the Court.

Issue (ii): Whether continuation of proceedings under the Prevention of Money Laundering Act, 2002 was barred after the closure report in the predicate FIR and in view of the petitioners' reliance on other pending or connected proceedings.

Analysis: The filing and acceptance of a closure report in one FIR did not conclude the matter for all purposes where the investigation had also taken into account numerous other FIRs alleging scheduled offences. The Court treated the existence of multiple FIRs and continuing material as sufficient to sustain the PMLA action, and held that the ECIR could continue to be acted upon notwithstanding the closure report in the solitary FIR relied upon by the petitioners.

Conclusion: The challenge based on closure of the predicate FIR was rejected.

Issue (iii): Whether the alleged conduct could be pursued only under the Banning of Unregulated Deposits Schemes Act, 2019 and not under the Indian Penal Code or the Prevention of Money Laundering Act, 2002.

Analysis: The Court held that the Banning of Unregulated Deposits Schemes Act, 2019 does not exclude the operation of other laws, because its saving clause provides that its provisions are in addition to and not in derogation of other laws. Accordingly, the mere possibility that the allegations may also fall within that special statute did not bar prosecution under the Indian Penal Code, nor did it nullify the scheduled-offence basis for PMLA action.

Conclusion: The argument that the BUDS Act excluded IPC and PMLA proceedings was rejected.

Issue (iv): Whether the alleged lack of repayment, the interim protection order, and the SFIO investigation barred continuation of the impugned proceedings.

Analysis: The Court held that the petitioners' explanation for non-repayment did not negate the prima facie allegation of cheating for the purposes of quashing. It also found no established breach of the interim protection order sufficient to invalidate the proceedings. Further, the SFIO investigation under the Companies Act, 2013 did not cover the petitioners themselves, and therefore did not bar the continuation of PMLA proceedings against them.

Conclusion: These additional grounds for quashing were rejected.

Final Conclusion: No ground was made out for exercising inherent jurisdiction to quash the PMLA proceedings, and the challenge to the impugned action failed in full.

Ratio Decidendi: For PMLA proceedings, continuation is not defeated merely because one predicate FIR ends in closure if other scheduled-offence material exists, and the special statute invoked by the accused does not bar prosecution under other laws where its own text preserves concurrent operation.

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