WhatsApp Banquet-Hall Plan And Alleged False Statement Keep Consultant In PMLA Trial Over Ranchi Land: Jharkhand HC

The Enforcement Directorate alleged that an 8.86-acre parcel known as “Lalu Khatal” was proceeds of crime connected with scheduled offences involving forged land and revenue records.

The petitioner, a partner of M/s Grids Consultants, allegedly prepared and revised a proposed banquet-hall plan identifying that location and shared it with a co-accused; the prosecution also relied on WhatsApp communications, survey proceedings, witness statements and the petitioner’s statement under Section 50 of the PMLA.

The petitioner was charged with knowingly assisting in concealing the co-accused’s possession and beneficial enjoyment of the land.

The Special Judge rejected his discharge application under Section 250 BNSS on 10 June 2026. During the revision, the trial court framed a charge under Sections 3 and 4 of the PMLA on 11 August 2026.

Section 250(2) of the BNSS permits discharge where, on considering the case record and hearing the parties, the court finds no sufficient ground to proceed; it corresponds to Section 227 CrPC.

Under Section 3 of the PMLA, knowingly assisting, being a party to, or being involved in a process connected with proceeds of crime—including concealment—may constitute money laundering; Section 4 prescribes punishment.

At discharge, the court must assess whether the prosecution material, taken at face value, discloses the offence and gives ground to presume its commission; grave suspicion may justify trial, but a mini-trial or assessment of the defence is impermissible (State of T.N. v. N. Suresh Rajan; Sajjan Kumar v. CBI).

Revisional interference is limited: it is warranted for patent legal or procedural error, perversity, or where the allegations taken at face value do not constitute an offence; revision is not an appeal for reappreciating evidence (Munna Devi v. State of Rajasthan).

The Court treated the banquet-hall plan as one part of the prosecution’s circumstantial case, not as isolated proof. The plan named “Lalu Khatal,” was shared with the co-accused, and was reportedly revised over several years; the prosecution also relied on employee evidence, survey records and witness identification of the disputed land by that name.

These materials could support a prima facie inference that the petitioner knew of the property and assisted in concealing its possession or use.

Whether the plan was merely professional work, whether the petitioner knew the land’s alleged criminal provenance, and whether his conduct amounted to knowing assistance were factual matters for trial, not discharge.

The Special Judge had considered the material and applied the appropriate threshold, so the order was not perverse or legally infirm.

Finding no illegality, perversity or other basis for revisional interference, it dismissed the criminal revision and disposed of any pending interlocutory applications.

The trial court was directed to decide the case independently of the High Court’s prima facie observations.