ECIR registration under PMLA depends on independent satisfaction and reasons to believe, not merely a predicate offence.

The Prevention of Money Laundering Act, 2002 requires an authorised officer to form an independent prima facie satisfaction on the materials available and record reasons to believe before initiating action. Registration of a predicate offence or the mere allegation of scheduled offences does not by itself compel the Enforcement Directorate to register an ECIR. ECIR is only an internal document, and the decision whether to proceed under the Act remains within the agency's statutory discretion. A court therefore cannot direct ECIR registration solely on the existence of a predicate offence.

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Issues: Whether the Enforcement Directorate can be directed to register an ECIR under the Prevention of Money Laundering Act, 2002 merely because a predicate offence is registered and scheduled offences are alleged.

Analysis: The Prevention of Money Laundering Act, 2002 creates a distinct mechanism for action on the basis of proceeds of crime. Registration of a predicate offence does not by itself compel the Enforcement Directorate to commence proceedings. The statutory scheme requires the authorised officer to form an independent prima facie satisfaction from the materials in possession and to act on recorded reasons to believe at the relevant stage. ECIR is only an internal document and the decision whether to initiate proceedings under the Act remains within the domain of the Enforcement Directorate. The existence of a scheduled offence, without more, is therefore insufficient to issue a direction compelling registration of ECIR.

Conclusion: The request for a direction to register ECIR was not maintainable on the facts pleaded and was rejected.

Final Conclusion: The petition failed because the court declined to substitute its own view for the Enforcement Directorate's statutory discretion to decide whether to proceed under the money-laundering law.

Ratio Decidendi: A court cannot compel registration of an ECIR under the Prevention of Money Laundering Act, 2002 solely on the existence of a predicate offence, because initiation of proceedings depends on the authorised officer's independent satisfaction based on materials and recorded reasons to believe.

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