In Brief
The Supreme Court quashed a complaint filed by the Directorate of Enforcement under the Prevention of Money-Laundering Act based on income-tax violations and conspiracy allegations. The Court held that Section 120B IPC becomes a scheduled offence only when the conspiracy relates to an offence specifically listed in the PMLA Schedule. Since the underlying offences were not scheduled offences, no proceeds of crime could exist. Without proceeds of crime, there is no offence under Section 3 PMLA. The Court emphasized that Special Courts must apply criminal procedure provisions to dismiss complaints lacking prima facie cases, rather than proceed mechanically. The complaint was quashed accordingly.
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