Suspended IAS Officer Denied Bail: 800 Photos, Google Search Expose Bribery System

The Gujarat High Court on Monday rejected the bail plea of suspended IAS officer R.M. Patel, a former Surendranagar collector, in a money laundering case linked to an alleged bribery racket involving land-use conversion approvals. Justice H.D. Suthar, in a 48-page judgment, held that Patel had "failed to satisfy the twin conditions under Section 45 of the PMLA Act" — namely, that there were no reasonable grounds to believe he was not guilty or unlikely to commit the offence again.

The Directorate of Enforcement (ED) presented extensive evidence before the court, including 800 photographs of land-use conversion applications found on Patel's personal phone. The ED argued these photographs constituted a "photographic trail" of every file that passed through his desk, allegedly carrying a specific price tag. Furthermore, the ED revealed that Patel's Google search history recorded a query — "how to reset Samsung S24 Ultra" — one day before the Enforcement Directorate searched his premises, suggesting an attempt to destroy evidence.

The ED described the case as "a system" and submitted that Patel, as the then collector, held final approval authority on the IORA portal and received the largest single share (50 per cent) of bribes, amounting to Rs 3.12 crore. The investigation began on December 23, 2025, when a search at the residence of Chandrasinh Mori, a deputy mamlatdar in the collector's office, yielded Rs 67.5 lakh in cash and handwritten "hisab sheets" (accounts) allegedly documenting bribes collected for Change of Land Use (CLU) permissions. The material was shared with the Anti-Corruption Bureau under Section 66(2) of the PMLA, leading to an FIR under the Prevention of Corruption Act, while the ED registered a separate money laundering case.

Additional Solicitor General S.V. Raju, appearing for the agency, informed the court that bribe rates had been standardised: Rs 10 per square metre for approvals under the Gujarat Land Revenue Code and Rs 5 per square metre under the Saurashtra Gharkhed Tenancy Settlement Ordinance. The alleged proceeds moved through a fixed hierarchy — 50 per cent to the collector, 25 per cent to the resident additional collector, 10 per cent each to the chitnis and mamlatdar, and five per cent to the clerk. Of the 842 CLU applications processed during the period under scrutiny, 501 fell within Patel's tenure.

The agency argued that Patel was not merely a beneficiary but the system's final authority. Digital approval powers on the IORA portal rested solely with him, and "files could not move further without the approval or rejection of the present applicant." The ED emphasised that Patel's powers distinguished him from co-accused who remain free — some could only record remarks, others only download files, and others had no approval role. The prosecution also relied on statements recorded under Section 50 of the PMLA, including those of Mori and advocate Chetan Kanzariya, who allegedly admitted paying Rs 65 lakh to Mori on behalf of applicants and described officials "creating problems in speedy clearance" and raising "clumsy queries" until money changed hands.

The ED pointed to additional circumstantial evidence: a commercial property purchased in Patel's wife's name at a declared value of Rs 9 lakh with the remaining consideration allegedly paid in cash; unaccounted jewellery worth Rs 2 lakh; purchase of an iPhone 17 Pro Max despite bank withdrawals of only Rs 3,500 during the year; and repeated cash deposits of Rs 49,000, allegedly structured to remain below the PAN reporting threshold.

Patel's counsel, Senior Advocate Sudhir Nanavati, challenged the ED's submissions, arguing that the evidence was circumstantial and that Patel had cooperated with the investigation. However, the court found the combination of factors — the 800 photographs, the Google search, the structured cash deposits, and the alleged hierarchy of bribes — sufficient to deny bail.

The judgment underscores the strict approach courts have taken under the PMLA, particularly with respect to the twin conditions for bail. Patel remains in custody as the investigation continues.