Dismissed¶28

S.P.Rajan v. The Assistant Director

Madras HC20 Jan 2026WP Crl./113/2026

Case brief

AI extract

What is this about?

PMLA summon challenge dismissed; ED/Directorate of Enforcement summon to an accused in the predicate offence cannot be quashed merely because the enquiry is complete and the charge-sheet filed; W.P.Crl.No.113 of 2026 and WP MP Crl.No.27 of 2026; S.P.Rajan v. Assistant Director, Directorate of Enforcement; writ of certiorari under Article 226 of the Constitution of India; Prevention of Money Laundering Act, 2002; Summon No.PMLA/Summon/CEZ0II/2025/1596 dated 18.12.2025; decided 20.01.2026; coram: Chief Justice Manindra Mohan Shrivastava and Justice G. Arul Murugan.

What did the court decide?

After registration of the predicate offence, the respondent authority had initiated proceedings under the Act and, in connection with the same, the petitioner has been summoned; the petitioner is an accused in the predicate offence. ¶27

S.P.Rajan Vs The Assistant Director — Money Laundering | Madras HC (2026)

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W.P.Crl.No.113 of 2026

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IN THE HIGH COURT OF JUDICATURE AT MADRAS

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DATED: 20.01.2026

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CORAM :

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THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND

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THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN

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W.P.Crl.No.113 of 2026 and WP MP Crl.No.27 of 2026

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S.P.Rajan S/o.VSP Subramanian, No.56-E, RITZ Hotel Road, Grace Hill, Coonoor, The Nilgiris.

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Petitioner

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The Assistant Director Directorate of Enforcement, Government of India, Greams Road, BSNL Building, Tower-II, Third Floor, Thousand Lights, Chennai -600 006.

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Respondent

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PRAYER: Petition filed under Article 226 of the Constitution of India seeking issuance of a writ of certiorari to call for the records relating to the File No.CEZ02/4/2022/2316 in Summon No.PMLA/Summon/CEZ0II/2025/1596 of the respondent dated 18.12.2025, and quash the same.

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_______________ Page 1 of 4_

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https://www.mhc.tn.gov.in/judis

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W.P.Crl.No.113 of 2026

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For Petitioner: Mrs.A.L.Ganthimathi Senior Counel for Mr.L.Palani Muthu

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For Respondent: Mr.N.Ramesh Special Public Prosecutor for ED Cases

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ORDER

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(Order of the Court was made by the Hon'ble Chief Justice)

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Heard learned counsel for the parties.

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Challenge to the summon issued by the respondent is premised mainly on the submission that, while making investigation into the predicate offence, a detailed enquiry was already made and whatever information required was also already collected. It is submitted that, in the predicate offence, charge-sheet has already been filed and, at this stage, no purpose would be served in issuing summon to the petitioner by the respondent authority in the proceedings under Prevention of Money Laundering Act, 2002 ( the Act ).

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_______________ Page 2 of 4_

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https://www.mhc.tn.gov.in/judis

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W.P.Crl.No.113 of 2026

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After going through the contents of the petition and the

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record, we find that after registration of the predicate offence, the respondent authority had initiated proceedings under the Act and in connection with the same, the petitioner has been summoned. The petitioner, undoubtedly, is an accused in the predicate offence. Therefore, the challenge to the summon only on such factual assertion is not tenable in law.

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The writ petition is dismissed. There shall be no order as to

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costs. Consequently, connected miscellaneous petition is closed.

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(MANINDRA MOHAN SHRIVASTAVA, CJ) (G.ARUL MURUGAN,J) 20.01.2026 Index : Yes/No Neutral Citation : Yes/No bbr

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To:

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The Assistant Director Directorate of Enforcement, Government of India, Greams Road, BSNL Building, Tower-II, Third Floor, Thousand Lights, Chennai -600 006.

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_______________ Page 3 of 4_

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https://www.mhc.tn.gov.in/judis

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W.P.Crl.No.113 of 2026

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THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J.

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bbr

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W.P.Crl.No.113 of 2026