The Gujarat High Court on Tuesday refused regular bail to suspended IAS officer and former Surendranagar collector Rajendrakumar Mahendrabhai Patel in a money laundering case linked to an alleged land conversion bribery racket. The court said corruption weakens constitutional governance and money laundering damages the country’s economic health.
Justice Hasmukh D Suthar passed the order while hearing Patel’s bail plea under the Prevention of Money Laundering Act (PMLA). The court held that Patel failed to satisfy the strict legal conditions required for bail under Section 45 of the law, Indian Express reported.
In an order delivered on June 29, the court said, “The main object of PMLA is to prevent money laundering. The economic health of the Nation needs to be protected and money laundering scars the economic condition of the nation as a whole. It is needless to say that the sovereignty of a nation always prevails over personal liberty.”
According to the Enforcement Directorate (ED), Patel received more than Rs 3.12 crore as illegal proceeds from a bribery network that allegedly operated inside the Surendranagar collectorate during his tenure. The agency claimed officials collected money from applicants seeking permission to convert agricultural land into non-agricultural use and distributed the amount among different officials through a fixed formula, reported Indian Express.
The ED calculated Patel’s alleged share at Rs 3,12,62,230 after examining 501 change of land use (CLU) applications that authorities processed during his tenure as district collector.
Why did Gujarat High Court refuse bail?
The court examined whether Patel met the two mandatory conditions under Section 45 of the PMLA. Under the law, the court must first find reasonable grounds to believe that the accused is not guilty of money laundering. It must also be satisfied that the accused will not commit any offence if released on bail. The court said that Patel did not clear either of these legal requirements.
The ED told the court that the alleged bribery racket came to light after officials recovered Rs 67.50 lakh in cash and “hisaab sheets” from the residence of deputy mamlatdar Chandrasinh Mori on December 23, 2025.
According to the agency, the records revealed a well-organised system for collecting bribes from people seeking land conversion approvals. The investigation claimed officials charged Rs 10 per square metre for applications filed under Sections 65 and 65B of the Gujarat Land Revenue Code, which deal with conversion of agricultural land into non-agricultural use. It also alleged that officials collected Rs 5 per square metre for applications under Sections 54 and 55 of the Saurashtra Gharkhed Tenancy Settlement and Agricultural Lands Ordinance.
The ED alleged that the money followed a fixed distribution pattern. According to its case, the collector received 50 per cent of the illegal amount, while the resident additional collector received 25 per cent. The mamlatdar and chitnis each received 10 per cent, and the clerk received the remaining 5 per cent.
The agency relied on handwritten account sheets, digital records, witness statements and material collected under Section 50 of the PMLA. It also claimed several witnesses said officials deliberately delayed approvals or raised unnecessary objections until applicants paid bribes.
Investigators also told the court that they recovered nearly 800 photographs of CLU files and applications from Patel’s email account. The court also took note of the ED’s claim that Patel attempted to reset his Samsung S24 Ultra mobile phone one day before the agency carried out its search operation.
The order said, “Such conduct speaks volume,” adding that the alleged attempt to erase data prima facie indicated possible evidence tampering and supported the agency’s allegations.
Patel said that the ED could not continue the money laundering case because investigators had not filed a chargesheet in the scheduled offence under the Prevention of Corruption Act.
The High Court did not accept this argument. It relied on earlier Supreme Court rulings and held that money laundering is an independent offence under the PMLA as long as the scheduled offence remains in existence. The court also said the ED has the power to continue its investigation while informing the appropriate investigating agency under Section 66(2) of the Act if it uncovers evidence relating to another offence.
Patel also sought parity with other accused persons who had not been arrested. The court rejected that submission as well. It said each accused must be assessed according to his own role and the evidence available against him. Since Patel allegedly served as the final authority for approving land conversion applications and allegedly received the largest share of the illegal money, his role stood on a different footing from others.
The court made strong observations on corruption in public life. It said corruption by government officials has become a serious challenge for constitutional governance, democracy and the rule of law.
The order said rampant corruption among senior public servants has caused economic unrest and harmed the country’s development. It added that Patel, as district collector, had a duty to perform his responsibilities with honesty, integrity and commitment but allegedly failed to do so.
The judge also referred to Lord John Dalberg Acton’s famous observation, saying, “Power tends to corrupt, and absolute power corrupts absolutely.” The court said the quote reflects the lasting danger of unchecked power over human conduct.
Patel also sought bail on medical grounds, saying he required arthroscopic surgery for a knee injury. The High Court held that the medical condition was neither life-threatening nor terminal. It ruled that he could receive treatment in jail or seek temporary bail if required for medical reasons.