Prima facie money-laundering case survives charge stage where prosecution material shows proceeds of crime and grave suspicion.

At the discharge and charge-framing stage under the Prevention of Money Laundering Act, the Court must only see whether the prosecution material discloses sufficient ground to proceed and a prima facie case; it cannot weigh the defence or conduct a mini trial, and revisional interference is limited to patent illegality or jurisdictional error. Applying that standard, the Court found no legal infirmity in the orders refusing discharge and framing charge. The investigation material was held to disclose proceeds of crime, linked to illegal stone mining, unaccounted cash, suspicious bank deposits, and routing of illicit funds, so a prima facie case of money-laundering was made out and the proceedings were allowed to continue.

---

---

Issues: (i) Whether the orders refusing discharge and framing charge under the Prevention of Money Laundering Act, 2002 suffered from legal error; (ii) Whether the materials collected in investigation disclosed a prima facie case of money-laundering against the petitioner.

Issue (i): Whether the orders refusing discharge and framing charge under the Prevention of Money Laundering Act, 2002 suffered from legal error?

Analysis: The governing test at the stage of discharge and framing of charge is whether the record and documents produced by the prosecution disclose sufficient ground for proceeding and a prima facie case, not whether the prosecution will ultimately secure conviction. The Court applied the settled principles that the accused's defence cannot be weighed at this stage, that the Court may only sift the prosecution material to see whether grave suspicion exists, and that revisional interference with an order framing charge or refusing discharge is warranted only in cases of patent illegality or jurisdictional error.

Conclusion: The orders refusing discharge and framing charge did not suffer from any legal infirmity warranting interference.

Issue (ii): Whether the materials collected in investigation disclosed a prima facie case of money-laundering against the petitioner?

Analysis: The investigation material showed that the petitioner was linked to large-scale illegal stone mining, possession of unaccounted cash, suspicious bank deposits, and assistance to a co-accused in routing and layering illicit funds. The Court treated the existence of scheduled offences as established from the multiple predicate FIRs and held that the material disclosed proceeds of crime, the petitioner's active involvement in possession, concealment, and projection of such proceeds, and the applicability of the statutory presumption at the appropriate stage. The contention that the petitioner was not named in the original predicate offence or that mining activity under the mining law alone could not attract the money-laundering statute was rejected.

Conclusion: A prima facie case of money-laundering was made out against the petitioner.

Final Conclusion: The revisional challenge failed because the prosecution material disclosed sufficient grounds to proceed, and the criminal proceedings under the money-laundering law were allowed to continue.

Ratio Decidendi: At the stage of discharge or framing of charge, the Court must confine itself to whether the prosecution material discloses sufficient ground for proceeding and a prima facie case of money-laundering, without conducting a mini trial or evaluating the defence on merits.

---