For the reasons aforesaid, we find that the impugned order dated 17.02.2025 in Spl.C.C.No.9 of 2022 on the file of the XIV Additional Special Court for CBI cases need not be interfered with. Consequently, this Court concludes that the revision is devoid of merits and the same is liable to be dismissed. The trial Court shall proceed with the case on merits, uninfluenced by the observations made on facts. 40. In the result, the Criminal Revision Case is dismissed. Consequently, connected Miscellaneous Petitions, if any, are closed. No costs. (S.M.SUBRAMANIAM J.)(MOHAMMED SHAFFIQ J.) 19-11-2025

2025:MHC:2623
IN THE HIGH COURT OF JUDICATURE AT MADRAS
RESERVED ON : 04.11.2025
PRONOUNCED ON : 19.11.2025
CORAM
THE HONOURABLE MR JUSTICE S. M. SUBRAMANIAM AND
THE HONOURABLE MR.JUSTICE MOHAMMED SHAFFIQ
CRL RC No. 1541 of 2025
Rahul Surana
S/o.Shri Dinesh Chand Surana,
Male aged about 36 years, A-34, 6th Street, Anna Nagar (East), Chennai – 600 102.
Petitioner(s)
Vs
1. The Assistant Director,
Directorate of Enforcement,
Chennai Zonal Office-I,
Govt. of India, Ministry of Finance,
No.2, Kushkumar Road,
BSNL Administrative Building, 5th and 6th Floor, Nungambakkam, Chennai – 600 034.
ECIR No.CEZO-1/05/2019
Respondent(s)
PRAYER
To call for the records and set aside the impugned order dated 17.02.2025 in Spl.C.C.No.9 of 2022 on the file of the XIV Additional Special Court for CBI Cases, Chennai.
For Petitioner(s): Mr.Shree Singh
for Mr.Vishnu Vardhan.J and Mr.Mayank Pandey
For Respondent(s): Mr.N.Ramesh
Special Public Prosecutor For ED Cases
JUDGMENT S.M.Subramaniam,J.
The Criminal Revision Case is directed against docket order, dated
17.02.2025 in Spl.C.C.No. 9 of 2022 on the file of XIV Additional Special
Judge for CBI cases/ Special Court for Trial of offences under Prevention of
Money Laundering Act, 2002 (hereinafter referred to as the “Act”).

I. FACTS:
2. The case of the prosecution is that Surana Industries Limited orchestrated a criminal conspiracy to defraud public sector banks of Rs.1,301 Crores through misappropriation, fraud, and manipulation of accounts. As per the Respondent, the modus operandi included creation of a web of shell and dummy companies to siphon loan funds via fictitious transactions, which were then layered and ultimately invested in movable and immovable properties as the alleged proceeds of crime.
3. The Enforcement Directorate filed a Main Prosecution Complaint under Section 44(1)(b) of the PMLA before the Special Court, Chennai on 09.09.2022 against 8 accused persons for offences punishable under Sections 3 and 4 of the PMLA, 2002. The Special Court took cognizance of the said Main Complaint on 25.11.2022 and registered the matter as Spl. C.C.No.9 of 2022. Subsequently, a First Supplementary Prosecution Complaint was filed on 11.6.2024 against 19 additional accused persons.
The said complaint was taken on file on 06.08.2024.The present petitioner,
Shri Rahul Surana, was not arrayed as an accused either in the Main
Complaint or in the First Supplementary Complaint. A Second Supplementary Prosecution Complaint was filed on 06.11.2024 against 15 additional accused persons, including the present petitioner (shown as Accused No. 42). The said complaint was taken on file and process was issued on 17.02.2025.The petitioner has now challenged the order dated 17.02.2025 primarily on the ground that he was not afforded an opportunity of being heard before the Special Court took cognizance, as allegedly required by the proviso to Section 223(1) of the BNSS.

4. In order to derive the essence behind the proviso to Section 223(1) of BNSS, it becomes imperative to discuss the meaning and character of the phrase ‘taking cognizance’ in the light of various decisions rendered by the Hon’ble Supreme Court of India.

II.COGNIZANCE MEANING:
5. Cognizance essentially means that the Judge should have applied his judicial mind and prima facie be satisfied that the allegations in the complaint, if proved, would constitute an offence.
6. Various decisions rendered by the Courts of law have explained the significance of the term cognizance. In R.R.Chari Vs State of Uttar Pradesh1, in para 8, the Hon’ble Supreme Court of India stated that the word “cognizance” is used by the Court to indicate the point when
Magistrate or a Judge first takes judicial notice of an offence. Therefore, it is understood that cognizance of an offence takes place, when a Judicial Magistrate applies his mind and takes judicial notice of the offence.
7. In Fakhruddin Ahmad Vs. State of Uttaranchal2, the Hon’ble

1 1951 SCC 250 2 (2008) 17 SCC 157
Supreme Court of India observed as follows:
“17. Nevertheless, it is well settled that before a Magistrate can be said to have taken cognizance of an offence, it is imperative that he must have taken notice of the accusations and applied his mind to the allegations made in the complaint or in the police report or the information received from a source other than a police report, as the case may be, and the material filed therewith. It needs little emphasis that it is only when the Magistrate applies his mind and is satisfied that the allegations, if proved, would constitute an offence and decides to initiate proceedings against the alleged offender, that it can be positively stated that he has taken cognizance of the offence. Cognizance is in regard to the offence and not the offender.”

8. So this observation points out two main characteristics of the words ‘taking cognizance’. One is that, the application of mind plays a pivotal role to fulfil the process of taking cognizance. So this procedure shall not be an empty formality. Second point is that cognizance is taken with regard to the offence and not the offender.
III.COGNIZANCE OF OFFENCE OR COGNIZANCE OF ACCUSED:
9. It is a well settled principle of criminal law that cognizance is taken of an offence and not of the offender. This principle has been further elaborated in Prasad Shrikant Purohit vs State of Maharastra . The relevant portion is extracted below:
“74. …While cognizance is already taken of the main offence against the accused already arrayed, the supplementary charge-sheet may provide scope for taking cognizance of additional charges or against more accused with reference to the offence already taken cognizance of and the only scope would be for the added offender to seek for discharge after the filing of the supplementary charge-sheet against the said offender.
75. In CREF Finance Ltd Vs. Shree
Shanthi Homes (P) Limted , this Court has held: ‘Cognizance is taken of the offence and not of the offender and, therefore, once the court on perusal of the complaint is satisfied that the complaint discloses the commission of an offence and there is no reason to reject the complaint at that
stage, and proceeds further in the matter, it must be held to have taken cognizance of the offence. One should not confuse taking of cognizance with issuance of process. Cognizance is taken at the initial stage when the Magistrate peruses the complaint with a view to ascertain whether the commission of any offence is
disclosed.”
In State of Andra Pradesh Vs. Pastor P. Raju , the Hon’ble Supreme Court held in paragraph 13 as follows:
“13. It is necessary to mention here that taking cognizance of an offence is not the same thing as issuance of a process. Cognizance is taken at the initial stage when the Magistrate applies his judicial mind to the facts mentioned in a complaint…”
10. Hence, these aforementioned judicial decisions clearly reinforces the legal principle that cognizance is of the offence and not the offender.
11. Also Explanation (ii) to Section 44 of PMLA specifically provides for supplementary complaints. The Explanation (ii) to Section 44 clarifies that the prosecution complaint shall be deemed to include any subsequent complaint in respect of further investigation that may be conducted to bring any further evidence, oral or documentary, against any accused person involved in respect of the offence, for which complaint has already been filed, whether named in the original complaint or not.
12. Hence, the language of the Section makes it clear that supplementary complaint is not a fresh or independent complaint but is deemed to be part and parcel of the main complaint in respect of which cognizance has already been taken. Taking multiple cognizance of the same offence would render the judicial process redundant and result in delay in the justice delivery process. Once cognizance of an offence is taken, any further supplementary prosecution complaint is considered as flowing from the main prosecution complaint for which the Court has already taken cognizance. So adding multiple layers of procedure to an already cognized complaint is a futile exercise.
13. In the present case, cognizance of the offence was already taken on 25.11.2022 and so the Second Supplementary Complaint does not involve taking cognizance afresh;
14. The daily order dated 17.02.2025, which states that “Cognizanceof the complaint as against the accused 28 to 42 taken can be understood as merely an error and can be ignored for the reason that cognizance cannot be taken again for the (i) 2nd time (ii) as against the accused. It shall be read as the Second Supplementary Complaint was taken on file on 17.02.2025, it was being added to the existing proceedings in Spl. C.C. No.9 of 2022 where cognizance had already been taken.
15. This cannot be construed as a material or substantive error. It is mere curable error of expression. This curable error can neither go to the extent of vitiating the entire proceeding nor can it result in miscarriage of justice.

16. The impugned order of the learned Trial Judge sufficiently demonstrates application of mind on the part of the learned Trial Judge. The order adequately showcases that materials placed before was perused and that prima facie opinion to the Trial Judge’s satisfaction was formed to proceed further. Hence, this shows that the learned Trial Judge has applied his judicial mind and issued summons as a consequence of taking cognizance. When the intent of the order is issuance of process based on the complaint, there does not arise a need for an elaborate or reasoned order. Brief Orders which convey the intent and satisfaction of the Learned Trial Judge on perusal of the materials before him is sufficient to pass the litmus test as laid down in law.
17. This can be further substantiated by the order of the Hon’ble Supreme Court in Pramila Devi & Others Vs State of Jharkhand6, wherein a question arose as to whether detailed reasons should be recorded while taking cognizance. The Hon’ble Supreme Court observed as follows:
“14. Time and again it has been stated by this Court that the summoning order under Section 204 of the Code requires no explicit reasons to be stated because it is imperative that the Magistrate must have taken notice of the accusations and applied his mind to the allegations made in the police report and the materials filed therewith.
15. In Kanti Bhadra Shah v. State of W.B. [(2000) 1 SCC 722: 2000 SCC (Cri) 303] the following passage will be apposite in this context:
(SCC p. 726, para 12)
“12. If there is no legal requirement that the trial court should write an order showing the reasons for framing a charge, why should the already burdened trial courts be further burdened with such an extra work. The time has reached to adopt all possible measures to expedite the court procedures and to chalk out

6 2025 INSC 560
measures to avert all roadblocks causing avoidable delays. It a Magistrate is to write detailed orders at different stages merely because the counsel would address arguments at all stages, the snail-paced progress of proceedings in trial courts would further be slowed down. We are coming across interlocutory orders of Magistrates and Sessions Judges running into several pages. We can appreciate if such a detailed order has been passed for culminating the proceedings before them. But it is quite unnecessary to write detailed orders at other stages, such as issuing process. remanding the accused to custody, framing of charges, passing over to next stages in the trial.”
(emphasis supplied)
16. In Nagawwa v. Veeranna Shivalingappa Konjalgi [(1976) 3 SCC 736: 1976 SCC (Cri) 507] this Court held that it is not the province of the Magistrate to enter into a detailed discussion on the merits or demerits of the case. It was further held that in deciding whether a process should be issued, the Magistrate can take into consideration improbabilities appearing on the face of the complaint or in the evidence led by the complainant in support of the allegations. The Magistrate has been given an undoubted discretion in the matter and the discretion has to be judicially exercised by him.
It was further held that: (SCC p. 741, para 5)
“5. … Once the Magistrate has exercised his discretion it is not for the High Court, or even this Court, to substitute its own discretion for that of the Magistrate or to examine the case on merits with a view to find out whether or not the allegations in the complaint, if proved, would ultimately end in conviction of the accused.”
17. In Chief Controller of Imports & Exports v. Roshanlal
Agarwal [(2003) 4 SCC 139: 2003 SCC (Cri) 788] this Court, in para
9, held as under: (SCC pp. 145-46)
“9. In determining the question whether any process is to be issued or not, what the Magistrate has to be satisfied is whether there is sufficient ground for proceeding and not whether there is sufficient ground for conviction. Whether the evidence is adequate for supporting the conviction, can be determined only at the trial and not at the stage of inquiry. At the stage of issuing the process to the accused, the Magistrate is not required to record reasons. This question was considered recently in U.P. Pollution Control Board v. Mohan Meakins Ltd. [(2000) 3 SCC 745] and after noticing the law laid down in Kanti Bhadra Shah v. State of W.B. [(2000) 1 SCC 722: 2000 SCC (Cri) 303] it was held as follows: (U.P.Pollution case [(2000) 3
SCC 745], SCC p. 749, para 6)
“6. The legislature has stressed the need to record reasons in certain situations such as dismissal of a complaint without issuing process. There is no such legal requirement imposed on a
Magistrate for passing detailed order while
issuing summons. The process issued to the accused cannot be quashed merely on the ground that the Magistrate had not passed a speaking order.'”
18. In U.P. Pollution Control Board v. Bhupendra Kumar Modi [(2009) 2 SCC 147: (2009) 1 SCC (Cri) 679] this Court, in para 23, held as under: (SCC p. 154)
“23. It is a settled legal position that at the stage of issuing process, the Magistrate is mainly concerned with the allegations made in the complaint or the evidence led in support of the same and he is only to be prima facie satisfied whether there are sufficient grounds for proceeding against the accused.”
19. This being the settled legal position, the order passed by the Magistrate could not be faulted with only on the ground that the summoning order was not a reasoned order.’
(emphasis supplied)
17. The view in Bhushan Kumar (supra) was reiterated in
Mehmood Ul Rehman v Khazir Mohammad Tunda, (2015) 12
SCC 420 and State of Gujarat v Afroz Mohammed Hasanfatta, (2019) 20 SCC 539. This Court in Rakhi Mishra v State of Bihar, (2017) 16 SCC 772 restated the settled proposition of law enunciated in Sonu Gupta v Deepak Gupta, (2015) 3 SCC 424, as under:
‘4. We have heard the learned counsel appearing for the parties. We are of the considered opinion that the High Court erred in allowing the application filed by Respondents 2, 4, 5, 6, 7, 8, 9 and 10 and quashing the criminal proceedings against them. A perusal of the FIR would clearly show that the appellant alleged cruelty against Respondents 2, 4, 5, 6, 7, 8, 9 and 10. This Court in Sonu Gupta v. Deepak Gupta [Sonu Gupta v. Deepak Gupta, (2015) 3 SCC 424: (2015) 2 SCC
(Cri) 265] held as follows: (SCC p. 429, para 8)
“8. … At the stage of cognizance and summoning the Magistrate is required to apply his judicial mind only with a view to take cognizance of the offence … to find out whether a prima facie case has been made out for summoning the accused persons. At this stage, the learned Magistrate is not required to consider the defence version or materials or arguments nor is he required to evaluate the merits of the materials or
evidence of the complainant, because the Magistrate

must not undertake the exercise to find out at this stage whether the materials would lead to conviction or not.”
5. The order passed by the trial court taking cognizance against R-2 and R-4 to R-9 is in conformity with the law laid down in the above judgment. It is settled law that the power under Section 482 CrPC is exercised by the High Court only in exceptional circumstances only when a prima facie case is not made out against the accused. The test applied by this Court for interference at the initial stage of a prosecution is whether the uncontroverted allegations prima facie establish a case.’
(emphasis supplied)”
18. Hence, the language of the impugned order does not show any irregularity and so the objection raised by the Petitioner at this stage cannot be entertained.
IV.PRE-COGNIZANCE HEARING:
19. The averments of the Petitioner that the benefit of pre-cognizance hearing as prescribed under proviso to sub-section (1) of Section 223 of BNSS was not given to the petitioner, cannot be applied to the present case, as it does not involve taking cognizance of the Main Prosecution Complaint for the first time. The issue before us is a challenge to the impugned order dealing with supplementary complaint. And as already discussed above the
Magistrate can take cognizance of an offence only for the first time.

20. Pre-cognizance hearing cannot be equated with a mini- trial. It is only for the Court to satisfy itself on jurisdiction and related procedural aspects. Any further delving into the factual defences or evidences at this stage should not be entertained.

21. Further reliance was placed by the Petitioner on the judgement rendered by the Hon’ble Supreme court in Kushal Kumar Agarwal Vs
Enforcement Directorate7, where the Hon’ble Court had made it crystal clear that the pre-cognizance hearing afforded to the accused is a mandatory procedure as stipulated under proviso to Section 223(1) of BNSS. So this admitted position of law does not stand disputed.
22. However, the facts in Kushal kumar case is clearly distinguishable from the present case. In Kushal kumar case, the Court was dealing with a fresh complaint and no prior cognizance had been taken of any offence. Therefore, the mandatory procedure as prescribed under proviso to Section 223(1) of BNSS was squarely applicable. But in the present case, cognizance was already taken on the main complaint filed on 09.09.2022 and as already discussed above supplementary complaint is considered as part and parcel of main complaint as per Explanation (ii) to section 44 of PMLA and hence taking fresh cognizance of the supplementary complaint has not arisen here so the procedure stipulated under proviso to Section
223(1) of BNSS finds no relevance to the present case.

V. STALE MATERIAL VS NEW MATERIAL:
23. The learned counsel for the Petitioner submits that the Purpose of

7 2025 SCC OnLine 1221
Explanation (ii) to Section 44, PMLA is two-fold:
(a) Read with Section 44(1)(b), PMLA, it explicitly confers the Special
Court with the power to take cognizance of a complaint filed by the
Enforcement Directorate. Both the CrPC and the BNSS only confer
Magistrates with the power of cognizance; and
(b) It explicitly recognizes supplementary complaints that are the result of “further investigation” to bring “further evidence, oral or documentary, against any accused person”.
24. It was also submitted by the Petitioner that the language used in respect of investigation and supplementary complaints in Explanation (ii) to Section 44, PMLA is identical to the language used in Section 173(8), CrPC (corresponding to Section 193(9), BNSS) i.e., “further investigation” and obtaining “further evidence, oral or documentary”.
25. In respect of “further investigation” under section 173(8), CrPC, the petitioner counsel placed reliance on Hon’ble Supreme Court Judgement in Mariam Fasihuddin Vs State of Karnataka , where it was reiterated that the terms “further investigation” must concern “further evidence, oral or documentary” that has been collected by the investigating agency. Thus, the provision for submitting a supplementary report (or a supplementary complaint) “infers that fresh, oral or documentary evidence should be obtained rather than re-evaluating or reassessing the material already collected and considered by the investigating agency while
submitting the initial police report”.
26. Hence the Petitioner contended that in the present case, the 2nd Supplementary Prosecution Complaint relies entirely on material dating from 2021 to 2023 i.e., material prior to the 1st Supplementary Prosecution Complaint and the Main Prosecution Complaint:
(a) The Petitioner’s statements under PMLA were recorded on
04.02.2021 and 05.02.2021;
(b) The searches at the premises of M/s Vedanta Farms (A40), M/s
Sunrise Farms (A41) were conducted on 04.02.2021 and 05.02.2021.
(c) The Provisional Attachment Order No. 07/2023 by which immovable properties in the name of the Petitioner’s partnership firms (A40 and A41) is dated 29.05.2023 and the same was confirmed by Learned Adjudicating Authority vide order dated 08.11.2023.
(d) The SFIO Complaint under Section 447, Companies Act, 2013, against the Petitioner and other accused filed on 09.09.2022 (SFIO
Complaint);
(e) The list of RUDs accompanying the 2nd Supplementary PC contains witness statements and documents entirely dating from 2021 to 2023.
27. Thus, relying on the above facts, the learned counsel for the Petitioner submitted that no fresh oral or documentary material has been collected against the Petitioner; in fact, the Enforcement Directorate relies entirely on material that was already collected and considered by the Enforcement Directorate at the time of filing of the Main Prosecution Complaint and the 1st Supplementary Prosecution Complaint. No explanation has been given by the Enforcement Directorate for arraigning the Petitioner in the 2nd Supplementary Prosecution Complaint based on older material already in its possession at the time of filing of the previous Prosecution Complaints.
28. On the contrary, Enforcement Directorate denied the contention of the petitioner that only ‘stale material’ was referred to. The counsel for the Enforcement Directorate submitted that the 2nd Supplementary Complaint dated 06.11.2024 is based on the complaint filed by the Serious Fraud Investigation Office (SFIO) under Section 447 of the Companies Act, 2013, before the Special Court at Chennai on 09.09.2022 (Spl.CC.No. 01/2023). This SFIO complaint constitutes fresh and new material that forms the basis of the present supplementary prosecution complaint under the PMLA.
29. The material particulars establishing that the SFIO complaint is new material are as follows:
(a) The SFIO complaint was filed on 09.09.2022, which was after the searches conducted in February 2021;
(b) The ECIR in the present case was initially registered on
27.12.2019 based on the CBI FIR;
(c) The ECIR was subsequently amended by way of Addendum dated 10.06.2024, specifically incorporating the SFIO Complaint as a scheduled offence;
(d) The SFIO complaint brought forth new allegations regarding corporate fraud, falsification of accounts, and violations under the Companies Act, 2013, which constitute a separate scheduled offence under the PMLA;
(e) The forensic audit report conducted by M/s.Haribhakti & Co., which forms part of the SFIO proceedings, constitutes fresh documentary evidence.
30. The Enforcement Directorate further submitted that the Petitioner has failed to appreciate the distinction between “pre-existing evidence” and “new material/fresh evidence.” The SFIO complaint, though based on transactions that occurred in the past, constitutes a new scheduled offence that came into existence only on 09.09.2022. This is fresh material for the purposes of the PMLA investigation.
31. It was also submitted that money laundering is a continuing offence and the very nature of this offence permits investigation into various layers of transactions, shell companies, and interconnected entities that are used to launder the proceeds of crime. The SFIO complaint revealed additional entities, transactions, and modus operandi that were not part of the original investigation based solely on the CBI FIR.

VI. RELIANCE ON MARIAM FASIHUDDIN CASE:
32. The aforesaid reply submitted by Enforcement Directorate was further met with a contention by the Petitioner on the ground that Enforcement Directorate had access to the SFIO Complaint for two years prior to the filing of the 1st Supplementary Prosecution Complaint, in which the Enforcement Directorate had decided not to arraign the Petitioner.
Reliance was placed on Enforcement Directorate’s averment in Paragraph
3.2 of the 1st supplementary PC (Page No. 476 of the Annexed set of Documents – II ) which clearly states that the SFIO complaint formed the basis of the said supplementary PC and also warranted an amendment dated 10.06.2024 to the original ECIR.
33. Therefore, there was no fresh material against the Petitioner that the Enforcement Directorate unearthed between the 1st Supplementary Prosecution Complaint and the 2nd Supplementary Prosecution Complaint and the law as held by the Hon’ble Supreme Court in Mariam Fashuddin ought to apply in the present case as well.
34. However, Enforcement Directorate submitted that the decision in
Mariam Fashuddin is factually distinguishable. Emphasis was placed on Para No.38 of the said judgment which reads as follows:
“38. It is a matter of record that in the course of ‘further investigation, no new material was unearthed by the investigating agency. Instead, the supplementary charge-sheet relies upon the Truth Lab report dated 15-7-2013, obtained by
Respondent 2, which was already available when
the original charge-sheet was filed…”
34. It was further substantiated by Enforcement Directorate that facts in Mariam Fashuddin are entirely different from the present case through the below mentioned factual differences;
i) The supplementary charge sheet was based on a report (Truth Lab report) that was already available at the time of filing the main chargesheet; ii) There was mere re-evaluation of existing material without any fresh investigation; iii) No new evidence, oral or documentary, was brought on record.
35. In stark contrast, in the present case:
(a) The SFIO complaint itself is a new scheduled offence that was registered on 09.09.2022;
(b) The forensic audit report by M/s Haribhakti & Co. constitutes fresh documentary evidence;
(c) The investigation was extended based on this new scheduled offence, not merely a re-appreciation of old material;
(d) The Addendum to ECIR dated 10.06.2024 specifically incorporated the SFIO complaint as a fresh predicate offence;
(e) The supplementary complaint reveals new entities (A-28 to A-42), new transactions, and expanded scope of money laundering activities.
36. Hence the SFIO complaint is not a mere re-evaluation of existing material but constitutes fresh evidence obtained during the course of further investigation.
37. In light of the above submissions, this Court finds that the SFIO complaint dated 09.09.2022 constitutes fresh and new material and that the supplementary complaint is not based on stale material and that the decision in Mariam Fashuddin is distinguishable and does not apply to the facts of the present case and hence the supplementary complaint is legally maintainable under Section 44(1) read with Explanation (ii) of the PMLA.
38. Therefore, from the above arguments, it can be deduced that the underlying transactions or events occurred in the past does not render the SFIO complaint “stale.” Hence this court finds merit in the argument that the scheduled offence itself (i.e., the SFIO complaint under Section 447 of the Companies Act) is a new development and cannot be termed as stale material.

39. For the reasons aforesaid, we find that the impugned order dated
17.02.2025 in Spl.C.C.No.9 of 2022 on the file of the XIV Additional Special Court for CBI cases need not be interfered with. Consequently, this Court concludes that the revision is devoid of merits and the same is liable to be dismissed. The trial Court shall proceed with the case on merits, uninfluenced by the observations made on facts.
40. In the result, the Criminal Revision Case is dismissed. Consequently, connected Miscellaneous Petitions, if any, are closed. No costs.
(S.M.SUBRAMANIAM J.)(MOHAMMED SHAFFIQ J.)
19-11-2025
gd
Index:Yes/No
Speaking/Non-speaking order
Internet:Yes
Neutral Citation:Yes/No
To
1.The Assistant Director,
Directorate of Enforcement, Chennai Zonal Office-I, Govt. of India, Ministry of Finance, No.2, Kushkumar Road, BSNL Administrative Building, 5th and 6th Floor, Nungambakkam, Chennai – 600 034. 
S.M.SUBRAMANIAM J.
AND
MOHAMMED SHAFFIQ J.

gd
CRL RC No. 1541 of
2025

19.11.2025