CASE STUDY - 3 Ratan Singh is a wholesale vegetable vendor. He has a shop in Jaipur Krishi Upaj Mandi. In the Mandi Yard, the Bank of Jaipur (BoJ) is having its branch, where Ratan Singh is operating his bank accounts since May, 2015. Until June, 2021, the transactions in the said bank account of Ratan Singh remained satisfactory but thereafter, some bulk credits and debits in the account happened which triggered system generated exception report. The branch manager inquired into the finacle system, to have an overview of profiling of the customer. Initially, the account was opened as a savings bank account (which is not meant for business transactions), the occupation was shown as private service, income ranging between ₹ 1 lakh to 5 lakh yearly, no complete KYC norms were followed and the account was not linked with Aadhar and PAN number. The branch manager, asked for retrieval of the physical documents, but the same were also not traceable at the branch level. The branch manager called on Ratan Singh in the branch to enquire about sudden hike in transactions in monetary terms, since it was not matching with the profile of the customer. The branch manager also insisted Ratan Singh to submit Re-KYC documents to enable the bank branch to update his profile. Ratan Singh informed that the transactions were on account of sale of his ancestral property situated in a village near Jaipur and purchase of another property in the Jaipur city. However, the manager was not convinced with the reply of the Ratan Singh since there were repeated transactions in bulk in the account. After bulk credits of amount in cash and subsequently followed by withdrawal, leaving bare minimum balance in the account created suspicious in the eyes of banker. The branch officials repeatedly asked Ratan Singh to submit the Re-KYC documents in order to do the Enhanced Due Diligence (EDD), else the transaction in his account will be stopped. Annoyed with this, Ratan Singh, finally decided to close the account in September, 2021. The Transaction Monitoring Team of the Bank reported the suspicious transactions to the Financial Intelligence Unit, India (FIU-IND), as a result, the Director asked certain information and relevant papers viz: identity of client, account file, and business correspondence etc. from the Bank relating to the account of Ratan Singh in November, 2022. The Mandi Yard branch of the Bank informed that since the account has already been closed in September 2021, they are not having any record / documents of the account of Ratan Singh. The branch informed that they do maintain records of the live accounts only and for closed accounts, they do not maintain any records relating to the profiling, account opening information, addresses proof, transaction monitoring etc. The Director re-acted based on information given by the Mandi Yard branch of the Bank and issued a show causes notice on the branch manager, stating therein, why a penalty should not be imposed on him for not adhering to the provisions of the Prevention of Money Laundering Act, 2002 (PMLA). The branch manager submitted the reply to the Director and gave reference of the Bank's Internal Circular, which do not stipulate to maintain the records of the closed transactions. The Director imposed maximum penalty as suggested in the PMLA on the Bank. Ratan Singh slowed down the business activity as vegetable vendor. He got in touch with the wild life hunters, who illegally hunt for the wild animals and used to illegally sell their skins, nails and bones at high very prices in India and abroad. Hunting of wild animals is an offence under 51 of the Wild Life (Protection) Act, 1972. Ratan Singh keeps the stock of such items at his residence. Ratan Singh earned a good amount of wealth 'during the past few years since he associated himself with wild life animal hunting activity. Ratan Singh purchased a 4 BHK flat in Jaipur in the name of Tara Devi, (his wife) and the consideration was paid by him out of the income which he earned from vegetable business for which he had earlier paid taxes and filed Income-tax returns. Ratan Singh's brother Shamsher Singh is not engaged in any gainful business and was fully dependent on him. To take care of Shamsher Singh, Ratan Singh also purchased a 3 BHK flat in the joint name of Shamsher Singh and Ratan Singh and the consideration was paid out of the income earned from wild life animal hunting activity. At one mid-night, when Ratan Singh was returning from Ranthambore Wild Life Sanctuary, to a Hotel in Dausa, he observed that a Police Jeep is coming behind his vehicle. At that time Ratan Singh was carrying skins of deer's in the vehicle. Although the skins of deer's were cleverly kept beneath the back seat of vehicle in a secret box, but Ratan Singh was afraid, if anything goes wrong. The Police Jeep followed the vehicle of Ratan Singh up to Hotel, and thereafter interrogated Ratan Singh and searched inside the vehicle. The prohibited items were found in the vehicle which was seized and Ratan Singh was arrested on the spot. The residence of the Ratan Singh was also searched at Jaipur by the Director and his team with the escort of Police and found wild life animal skins and other materials, cash gold jewellery and some property papers. The Director made out a detailed list of the items found and seized and obtained the signature of Ratan Singh and filed a case before the Adjudicating Authority. After a certain period of time, some family dispute arose between Shamsher Singh and Ratan Singh. Due to this unfortunate situation, Ratan Singh strongly informed Shamsher Singh that since the consideration for the purchase of 3 BHK was paid by him only and nothing was contributed by Shamsher Singh, and therefore, he should immediately vacate and hand over the possession of the property to Ratan Singh. Ratan Singh also forced Shamsher Singh to execute a Power of Attorney in favour of Ratan Singh, so that he (Ratan Singh) may sell the property. However, Shamsher Singh did not agree. Rather, Shamsher Singh told that since he is the first name holder of the property, so he have every right to retain it. The Initiating Officer (IO) based on the records collected from the Registry Office, issued a notice to Ratan Singh to submit certain explanation and information relating to the 3 BHK flat standing in the name of Shamsher Singh and Ratan Singh. Ratan Singh appeared before the IO with his Counsel but could not convince the IO. The IO, ordered for provisional attachment of the subjected property. The matter thereafter, was referred to the Adjudicating Authority (AA), wherein, the AA, after following the due procedures, held the property as benami and ordered for its confiscation. Aggrieved by the Order of the AA, Ratan Singh preferred an appeal before the Appellate Authority, where it upheld the decision given by the AA. Ratan Singh consulted a senior Advocate to file the matter before the High Court. However filing of the application before the High Court, Ratan Singh died in a road accident. In the light of the above facts and inputs, please answer the following questions as found in Part A and Part B: PART - A