SUSPENDED IAS officer R M Patel’s personal phone, the Directorate of Enforcement (ED) has told the Gujarat High Court (HC), held 800 photographs of land-use conversion applications – a photographic trail of every file that passed through his desk, each one allegedly carrying a price tag. One day before the ED searched his premises, his Google history recorded a query – “how to reset Samsung S24 Ultra,” the agency submitted in court.
The HC found that combination difficult to overlook and rejected the bail plea of the former Surendranagar collector in a money laundering case linked to an alleged bribery racket in his own office, Justice H D Suthar of the Gujarat HC, in a 48-page judgment delivered on Monday, held that Patel had “failed to satisfy the twin conditions under Section 45 of the PMLA Act” – in absence of reasonable grounds to believe that (Patel) is not guilty or unlikely to commit the offence again.”
The ED, which described the case as “a system”, submitted before the court 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 traces back to December 23, 2025, when a search at the residence of Chandrasinh Mori, then a deputy mamlatdar in the Collector’s office, yielded Rs 67.5 lakh in cash and handwritten “hisab sheets” (accounts) that allegedly documented 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, resulting in an FIR under the Prevention of Corruption Act, while the ED opened its own ECIR and later registered a money laundering case.
Appearing for the agency, Additional Solicitor General S V Raju told the court that bribe rates had effectively 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 judgment notes.
The alleged proceeds, according to the ED noted by the court, 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, the ED argued in court, and “files could not move further without the approval or rejection of the present applicant.”
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The agency submitted that the powers Patel possessed distinguished him from co-accused who remain free. The ED detailed that while one co-accused had only the power to record remarks, another could merely download files, while others had no approval role at all. The prosecution also leaned heavily 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 other circumstances it said supported its case – 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.
The court recorded the ED’s submission that “prior to one day of the raid, the applicant has tried to reset his mobile being Samsung S24 Ultra”, describing it as an attempt to destroy evidence.
Patel’s counsel, Senior Advocate Sudhir Nanavati, challenged the submissions. He contended that the PMLA proceedings could not survive without a predicate offence in existence at the time the ECIR was registered. The allegations, he submitted, rested almost entirely on co-accused statements without independent corroboration. Nanavati argued that the alleged system predated Patel’s appointment as Collector in February 2025 and pointed out that predecessor officials continued in service and had not even been questioned.
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Searches of Patel’s residence yielded no incriminating documents beyond electronic devices, his counsel submitted. Patel’s counsel also pointed out that the ED itself had sought no further custodial interrogation after the initial five-day remand. The counsel also relied on a medical ground, citing a knee injury requiring arthroscopic surgery, and argued that continued incarceration during a lengthy trial offended Article 21 protections.
Remaining unconvinced, the HC said in its judgement, “The present applicant-accused is involved in white collar socio-economic offence which constitute a class apart and needs to be visited with a different approach. The economic offences adversely affect the economic and social fabric of the country.”
On the 800 photographs, the HC held that they “clearly indicate that such photographs were not kept for supervision or to track timely disposal of applications,” rejecting any innocent explanation for their existence and the matter of the phone reset, it said, “is nothing but amounts to tampering with evidence.”
The court also rejected Patel’s challenge to the maintainability of the PMLA case, holding that “the predicate offence is not a sine qua non (essential condition) under PMLA” and rejected the plea that the co-accused are not arrested.
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Invoking Lord Acton’s warning that “power tends to corrupt, and absolute power corrupts absolutely”, the court observed that as district administrative head, Patel ought to have acted “with integrity, commitment and with righteous approach in the good faith of public at large,” but had instead allegedly allowed corruption to continue “with an open eye.”
Quoting the Supreme Court’s description of economic offences as crimes committed with “cool calculation and deliberate design”, the court described the allegations as a “white collar socio-economic offence which constitute a class apart.”
The medical condition, the court said, was neither serious nor life-threatening and could be treated in custody. Nor was five-and-a-half months in custody sufficient to establish delay, it said. The court said, “It is needless to say that the sovereignty of the nation always prevails over personal liberty.”