Prima facie discharge scrutiny under PMLA limits revisional interference where the record shows conscious consideration of material.

At the discharge stage under the Prevention of Money Laundering Act, the court is confined to a prima facie assessment of whether there are sufficient grounds to proceed, and it need not conduct a roving enquiry or finally determine guilt. An order must be read as a whole with the material considered, including the predicate offence, ECIR, section 50 statement, and property-related records. Where that record shows conscious consideration and a prima facie view to proceed, revisional interference is not justified merely because the court has not finally adjudicated the merits; on that basis, the discharge petition's dismissal was upheld.

---

---

Issues: Whether the dismissal of the discharge petition in the prosecution under the Prevention of Money Laundering Act, 2002 suffered from non-application of mind or perversity warranting interference in revision.

Analysis: The stage of discharge requires only a prima facie assessment to see whether there is sufficient ground for proceeding, and not a roving enquiry or final determination of guilt. The order under challenge was read as a whole, together with the materials noticed in it, including the predicate crime, the ECIR, the recorded statement under section 50 of the Prevention of Money Laundering Act, 2002, and the property-related materials relied upon by the prosecution. On that reading, the trial court had applied its mind to the relevant record and reached a prima facie view that there were materials to proceed. The revisional challenge did not establish that the order was non-speaking in substance, perverse, or based on no consideration of the record.

Conclusion: The dismissal of the discharge petition was upheld and no interference in revision was warranted.

Ratio Decidendi: At the discharge stage, the court is confined to a prima facie evaluation of the material and, where the order shows consideration of the relevant record as a whole, revisional interference is not justified merely because the court does not finally adjudicate the merits.

---