Gujarat HC denies bail to suspended IAS officer in money laundering-linked bribery case

THe gujerat heights margaret court rejected the habitue bond plea of suspended IAS officer Rajendrakumar Patel, holding that there was prima facie material to show his involvement in a money laundering case linked to an alleged land conversion bribery racket in the Surendranagar Collector’s office.Justice Hasmukh D Suthar, in an order dated June 29, said that Patel had failed to satisfy the conditions for bail under Section 45 of the Prevention of Money Laundering Act (PMLA), observing that there were “no reasonable grounds to believe he was not guilty” of the offence.The court said that economic offences such as money laundering adversely affect the country’s economic and social fabric and therefore require a different approach while considering bail. HT has reviewed a copy of the 48-page order.The Enforcement Directorate (ED) has alleged that Patel, a 2015-batch IAS officer who served as Surendranagar Collector from February 2025, headed an organised bribery network for processing change of land use (CLU) applications.According to the agency, Patel’s alleged share has been quantified at ₹3.12 crore from 501 CLU applications processed during his tenure.The court also noted ED’s claim that 800 photographs of CLU applications and related files were recovered from Patel’s email account, forming part of the digital evidence relied upon by the agency.According to ED, bribe rates had been fixed at ₹10 per sq/m for applications under sections 65 and 65B of the Gujarat Land Revenue Code and ₹5 per sq/m for applications under Sections 54 and 55 of the Saurashtra Gharkhed Tenancy Settlement and Agricultural Lands Ordinance, 1949.The court recorded ED’s allegation that the proceeds were distributed with 50% going to the collector, 25% to the resident additional collector, 10% each to the chitnis and deputy mamlatdar and 5% to the clerk.The court said the agency had relied on alleged “hisaab sheets”, digital evidence and statements recorded under Section 50 of PMLA.The case stems from a search conducted by ED on December 23, 2025, at the residence of deputy mamlatdar Chandrasinh Mori, during which ₹67.5 lakh in cash and alleged “hisaab sheets” recording bribe collections were recovered. Based on information shared by ED under Section 66(2) of PMLA, the Anti-Corruption Bureau (ACB) registered a corruption case against Patel and other officials.While rejecting the bail plea, the court also referred to ED’s allegation that Google activity records showed Patel had searched “how to reset Samsung S24 Ultra” a day before the ED raid and observed that this prima facie amounted to an attempt to tamper with evidence.ED further alleged that a commercial shop was purchased in Patel’s wife’s name by declaring only ₹9 lakh in the registered document while the remaining amount was paid in cash. It also alleged that jewellery worth ₹2 lakh had been purchased for his wife, that rental income and other funds were routed through the accounts of his wife and mother, and that multiple cash deposits of ₹49,000 each were made to remain below the threshold requiring PAN disclosure.The order further recorded ED’s submission that advocate Chetan Kanzariya said he had paid ₹65 lakh to Mori on behalf of persons seeking CLU approvals under prevailing rates, alleging that officials delayed applications and raised objections until bribes were paid.Patel, through his counsel, argued that no charge sheet was filed in the predicate corruption case, that he had not been arrested in the ACB case and that PMLA proceedings could not continue without a valid scheduled offence. He also contended that no incriminating material was recovered from his residence, that the allegations were based largely on statements of co-accused and that other officials allegedly involved had not been arrested. He also sought bail on medical grounds, citing a knee injury requiring surgery.Rejecting these submissions, the court held that money laundering is an independent offence and that the absence of a charge sheet in the predicate offence does not by itself entitle an accused to bail under PMLA.ED submitted that Patel, as district collector, was the sole authority empowered to grant final digital approval to CLU applications on the IORA portal and therefore could not claim parity with other officials who had not been arrested as they did not possess comparable decision-making powers.The court observed that Patel’s knee condition was not sufficient to warrant regular bail and that he could seek appropriate relief separately if surgery became necessary. It also noted that while investigation relating to Patel had concluded, ED had indicated that further investigation into concealment of proceeds of crime was continuing and that a supplementary complaint could be filed.“As district administrative head, applicant ought to have performed his duty with integrity, commitment and with righteous approach in the good faith of public at large though he indulged in corrupt practice and continued to allow the corruption in the office with an open eye,” the court observed in its order while dismissing the bail application.