Retention of frozen bank accounts under money-laundering law upheld where timely authorisation and prima facie laundering material existed.

Section 20 of the Prevention of Money-Laundering Act permits frozen property to remain under restraint beyond 180 days only if retention or continuation is authorised within the statutory framework. The record showed that the retention order was passed within time, so the freezing of the bank accounts did not lapse merely because 180 days had expired. The material also indicated the appellant's involvement in the alleged laundering activity, including his recorded statement, role in inspections and RMA proposals, and no satisfactory explanation for the source of the balances. On that basis, the accounts were treated as prima facie involved in money-laundering and liable to remain frozen.

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Issues: Whether the retention and continuation of freezing of the appellant's bank accounts was valid under the Prevention of Money-Laundering Act, 2002, including the contention that the freezing could not subsist beyond 180 days.

Analysis: Section 20 provides that where property is seized or frozen and the authorised officer forms the requisite belief, the property may be retained or continue to remain frozen for a period not exceeding 180 days, and the property may remain frozen beyond that period if the Adjudicating Authority permits retention or continuation of freezing. The material showed that the retention order was passed within the statutory period, so the freezing did not lapse merely with the passage of 180 days. The record also disclosed the appellant's involvement in the alleged laundering activity, including his recorded statement, role in inspections and RMA proposals, and the absence of a satisfactory explanation for the source of the bank balances. That material was sufficient to support the conclusion that the accounts were prima facie involved in money-laundering and were liable to be retained.

Conclusion: The challenge to the retention of the frozen bank accounts failed, and the appeal was not maintainable on merits.

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