Natural justice and source of cash challenges fail where relied upon documents were supplied and seized property remained unexplained.

The retention of seized cash and connected articles was sustained because the appellant was found to have received the relied upon documents, namely the punchnamas, and no further document relied on by the respondents was shown to have been withheld. A complaint of breach of natural justice therefore failed. On the merits, the appellant did not satisfactorily explain the source of the cash at the time of search or through later material, and the prosecution complaint already sought confiscation of the seized amount. On that basis, continued retention of the cash, documents and digital devices was held justified and the retention order was affirmed.

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Issues: (i) Whether the impugned retention order was vitiated for non-supply of relied upon documents and breach of natural justice; (ii) whether retention of the seized cash and articles was justified despite the appellant's challenge to the source of the cash.

Issue (i): Whether the impugned retention order was vitiated for non-supply of relied upon documents and breach of natural justice.

Analysis: The relied upon documents were the punchnamas forming part of the record, and copies of those documents had been supplied to the appellant. No other document was shown to have been relied upon by the respondents. The appellant also did not invoke the statutory course for obtaining further documents. On that basis, the complaint of procedural illegality or denial of natural justice was not established.

Conclusion: The challenge based on non-supply of relied upon documents fails, and no breach of natural justice is made out.

Issue (ii): Whether retention of the seized cash and articles was justified despite the appellant's challenge to the source of the cash.

Analysis: The prosecution complaint had already been filed naming the appellant as an accused, and confiscation of the seized amount was sought therein. The appellant failed to satisfactorily disclose the source of the cash at the time of search or by the later documents produced, which did not reliably establish a genuine source of funds. In these circumstances, the seizure and continued retention of the cash, documents, and digital devices were treated as justified.

Conclusion: The retention of the seized cash and articles is upheld.

Final Conclusion: The appeal is devoid of merit and the impugned retention order stands affirmed.

Ratio Decidendi: Where the relied upon documents are supplied and the appellant fails to substantiate the legitimate source of seized cash, continued retention of the property is sustainable under the money-laundering framework.

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