PMLA proceedings depend on a surviving scheduled offence; acceptance of the closure report made the action unsustainable.

Money-laundering proceedings under PMLA were held unsustainable where the predicate scheduled offence had ended in acceptance of the closure report and no contrary order existed. The Tribunal applied the principle that proceedings for proceeds of crime depend on the existence of a surviving scheduled offence, and distinguished authorities cited by the appellant because they arose in different procedural settings. On the facts, the criminal court's acceptance of the closure report continued to operate, so the PMLA action could not be maintained and the appeal was not fit for admission.

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Issues: Whether proceedings under the Prevention of Money-laundering Act, 2002 could survive when the scheduled offence had culminated in acceptance of the closure report and no scheduled offence remained pending.

Analysis: The appeal was examined in the light of the settled principle that money-laundering proceedings are dependent on the existence of a scheduled offence and the related allegation of proceeds of crime. The closure report in the predicate case had been accepted by the trial court, and that factual position was not effectively disputed. The cited authorities relied upon by the appellant were found distinguishable on facts, as they concerned different procedural contexts, including quashing proceedings, pending parallel offences, or criminal revision before a court having appropriate jurisdiction. On the facts before the Tribunal, the order of the criminal court accepting the closure report continued to operate, and no contrary order had been shown to exist.

Conclusion: In the absence of a surviving scheduled offence, the PMLA proceedings could not be sustained, and the appeal was not fit for admission.

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