C. Anandane Vs Directorate of Enforcement (Madras High Court)
Summary: The Madras High Court allowed a criminal revision petition challenging the order dated 18.12.2024 framing charges in Spl.C.C.No.2 of 2022 and a criminal original petition seeking quashing of the complaint filed by the Directorate of Enforcement under Sections 44(1) and 45(1) of the Prevention of Money Laundering Act, 2002. The Central Bureau of Investigation had registered the predicate offence against the petitioners under Section 13(2) read with Section 13(1)(e) of the Prevention of Corruption Act, 1988.
The petitioners, arrayed as accused Nos.1 and 2 in the predicate case, were convicted by the trial Court on 30.10.2018 and sentenced to one year’s rigorous imprisonment with fine. Based on that scheduled offence, the Directorate of Enforcement filed the PMLA complaint, which was taken on file as Spl.C.C.No.2 of 2022. Subsequently, the Madras High Court, by judgment dated 05.08.2026 in Crl.A.Nos.710 and 724 of 2018, allowed the petitioners’ appeals and set aside their conviction and sentence.
Relying on Vijay Madanlal Choudhary v. Union of India, the petitioners contended that the PMLA prosecution could not survive their acquittal in the predicate case. The High Court observed that the charge for the offence under Section 3 of the Prevention of Money Laundering Act, 2002 arose from the predicate case in which the petitioners had since been acquitted.
Want to Read the Complete Judgment?
You have read the free case summary. Unlock the full judgment, the detailed judicial reasoning and the downloadable PDF, along with every other premium judgment on TaxGuru.
Already subscribed? Log in
One subscription covers the entire premium judgment library, not just this case.
