Delhi High Court PMLA Digest 2025

Update: 2026-01-04 11:30 GMT
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'Not A Minor Offence, Part Of Crime Syndicate': Delhi HC Denies Bail To PMLA Accused Booked For Supplying Spurious Anti-Cancer MedicinesCase title: Lovee Narula vs.Directorate Of EnforcementCitation: 2025 LiveLaw (Del) 115The Delhi High Court has denied bail to an accused/applicant booked under the Prevention of Money Laundering Act, 2002 (PMLA) for his alleged involvement in the...

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'Not A Minor Offence, Part Of Crime Syndicate': Delhi HC Denies Bail To PMLA Accused Booked For Supplying Spurious Anti-Cancer Medicines

Case title: Lovee Narula vs.Directorate Of Enforcement

Citation: 2025 LiveLaw (Del) 115

The Delhi High Court has denied bail to an accused/applicant booked under the Prevention of Money Laundering Act, 2002 (PMLA) for his alleged involvement in the illegal procurement of empty vials and raw materials of anti-cancer drugs.

Justice Chandra Dhari Singh in his order said, "In the present case, the applicant has not been charged for some minor offence that has simple economic ramifications, rather he has been charged for supplying and selling of spurious life saving anti-cancer medicines and that he is part of an established crime syndicate. This factual position does not satisfy the consciousness of this Court and there are considerable reasons to believe that there is likelihood that the applicant might commit offence while on bail as the applicant does not have clean criminal antecedents. Thus, the said argument stands rejected".

Delhi High Court Quashes PMLA Proceedings Against BPSL In ₹47,000 Crore Bank Fraud Case Due To Successful CIRP

Case title: Bhushan Power & Steel Limited vs. Union Of India & Anr.

Citation: 2025 LiveLaw (Del) 146

The Delhi High Court has quashed criminal proceedings against Bhushan Power & Steel Limited (BPSL) in relation to a complaint filed by the Enforcement Directorate (ED) under the Prevention of Money Laundering Act, 2002 (PMLA) in view of Section 32A of the Insolvency and Bankruptcy Code (IBC).

Delhi High Court Grants Bail To Christian Michel Booked By ED In AgustaWestland Chopper Scam

Case Title: Christian Michel James v. ED

Citation: 2025 LiveLaw (Del) 273

The Delhi High Court has granted bail to British Arms Counsultant Christian James Michel in the FIR registered by Enforcement Directorate (ED) in connection with the Agusta Westland chopper scam.

Title: RAMESH CHANDRA v. THE DIRECTORATE OF ENFORCEMENT

Citation: 2025 LiveLaw (Del) 350

The Delhi High Court granted bail to 86-year-old founder of Unitech Group Ramesh Chandra, in a money laundering case registered by the Enforcement Directorate (ED).

Delhi High Court Asks Trial Court To Defer Arguments On Charge In Money Laundering Cases Against Karti Chidambaram

Title: KARTI P. CHIDAMBARAM v. ED & other connected matter

Citation: 2025 LiveLaw (Del) 440

The Delhi High Court has asked the trial court to defer arguments on charge in the money laundering cases related to Chinese visa and Aircel Maxis cases registered against Congress MP Karti Chidambaram.

AgustaWestland Scam: Delhi High Court Modifies Christian Michel's Bail Conditions In ED Case

Case Title: Christian Michel James v. ED

Citation: 2025 LiveLaw (Del) 600

The Delhi High Court modified the bail condition imposed on British Arms Counsultant Christian James Michel in the FIR registered by Enforcement Directorate (ED) in connection with the Agusta Westland chopper scam.

S.45 PMLA | Delhi High Court Grants Interim Bail To Money Laundering Accused On Ground Of Illness Of Family Member

Case title: Lovee Narula v. ED

Citation: 2025 LiveLaw (Del) 686

The Delhi High Court granted interim bail to an accused under the Prevention of Money Laundering Act 2002 to attend to his critically ill mother and to make necessary arrangements for her continued medical treatment.

Though the Enforcement Directorate submitted that the ground of illness of a family member of the accused is not available under Section 45 of PMLA, Justice Tejas Karia granted the relief on humanitarian grounds.

Jurisdiction Of Arbitral Tribunal Continues Despite Provisional Attachment Of Assets Under PMLA Or Parallel Proceedings: Delhi High Court

Case Title: LATA YADAV versus SHIVAKRITI AGRO PVT. LTD & ORS.

Citation: 2025 LiveLaw (Del) 696

The Delhi High Court bench of Justice Amit Mahajan has held that the mere reference to certain assets in a provisional attachment order does not, by itself, oust the jurisdiction of the arbitral tribunal. Similarly, the pendency of parallel investigations by the CBI or ED into allegations of fraud does not bar the arbitrator from adjudicating the dispute. Arbitration proceedings can continue independently, even when some aspects of the subject matter are under criminal investigation.

Delhi High Court Dismisses Bollywood Actor Jacqueline Fernandez's Plea To Quash Rs. 200 Crore Money Laundering Case

Title: JACQUELINE FERNANDEZ v. DIRECTORATE OF ENFORCEMENT

Citation: 2025 LiveLaw (Del) 742

The Delhi High Court dismissed a plea moved by Bollywood actress Jacqueline Fernandez seeking quashing of Rs. 200 crores money laundering case involving alleged conman Sukesh Chandrasekhar.

Justice Anish Dayal said that her apprehension that any evidence would be self-incriminating cannot lead to quashing of the ECIR as statutory and constitutional protections are already provided and will have to be assessed in that rubric.

SC's Vijay Madanlal Judgment Doesn't Exempt Foreign Recipients Of Proceeds Of Crime From Scrutiny On Mere Contractual Legitimacy Of Transaction: Delhi HC

Case title: Amrit Pal Singh v. ED

Citation: 2025 LiveLaw (Del) 759

The Delhi High Court has made it clear that foreign recipients of proceeds of crime are not exempted from scrutiny under the Prevention of Money Laundering Act, 2002, on a mere ground of 'contractual legitimacy' of transactions.

Delhi High Court Grants Anticipatory Bail To NewsClick Founder Prabir Purkayastha In ED, EOW Cases Alleging Foreign Funding

Title: Prabir Purkayastha v. ED and other connected matters

Citation: 2025 LiveLaw (Del) 834

The Delhi High Court granted anticipatory bail to Prabir Purkayastha, editor-in-chief and founder of news portal NewsClick, in Enforcement Directorate's money laundering case as well as Delhi Police's EOW FIR concerning allegations of foreign funding.

Justice Neena Bansal Krishna pronounced the verdict and disposed of the pleas filed by Purkayastha in 2021.

Being 'Sick And Infirm' Not Automatic Passport For Bail In PMLA, Medical Plea Can't Override Gravity Of Offence: Delhi High Court

Title: Arvind Dham v. ED

Citation: 2025 LiveLaw (Del) 993

Underscoring that being “sick and infirm” is not an automatic passport for bail in PMLA cases, the Delhi High Court has observed that medical plea cannot override the gravity of offence of money laundering.

Allowing Retention Of Seized Property Without Strictly Following PMLA Undermines Purpose Of Procedural Safeguards: Delhi High Court

Title: DIRECTORATE OF ENFORCEMENT THROUGH ASSISTANT DIRECTOR DELHI v. RAJESH KUMAR AGARWAL

Citation: 2025 LiveLaw (Del) 1104

The Delhi High Court ruled that allowing retention of seized property without strict adherence to PMLA provisions would amount to a violation of the legislative mandate of the enactment and would undermine the very purpose of incorporating procedural safeguards therein.

Confirmation Of Attachment Under PMLA Does Not Authorize Property Retention, Valid Order Must: Delhi High Court

Title: ANIRUDH PRATAP AGARWAL v. ENFORCEMENT DIRECTORATE

Citation: 2025 LiveLaw (Del) 1199

The Delhi High Court has observed that the confirmation of attachment of property involved in money laundering under Section 8(3) of PMLA does not authorize retention of such a property, as the process requires a valid order to be passed under Section 20.

Delhi High Court Says ED's Approach Of Not Arresting Main Accused 'Arbitrary', Grants Bail To Others

Title: VIPIN YADAV v. DIRECTORATE OF ENFORCEMENT & other connected matters

Citation: 2025 LiveLaw (Del) 1203

The Delhi High Court has granted bail to three men in a money laundering case, while saying that the approach of the Enforcement Directorate (ED) in not arresting the main accused with graver role was “manifestly arbitrary.”

ED Can Treat Coal Block Allocation Obtained By Deceit As 'Property' Involved In Money Laundering: Delhi High Court

Title: ED v. M/S. HI-TECH MERCANTILE INDIA PVT LTD & ORS. & ORS

Citation: 2025 LiveLaw (Del) 1320

The Delhi High Court has held that coal block allocation obtained through misrepresentation or fraud leading to proceeds of crime amounts to an offence of money laundering under the PMLA.

Profits Earned On Bribe After Investment In Share Market Also Part Of Proceeds Of Crime, Can Be Attached Under PMLA: Delhi High Court

Title: ED v. M/S PRAKASH INDUSTRIES LTD & other connected matter

Citation: 2025 LiveLaw (Del) 1432

The Delhi High Court ruled that the profits earned on bribe money after investment in share market amounts to proceeds of crime and is liable to be attached under the PMLA.

Provisional Attachment Order Can't Be Challenged In Writ Jurisdiction When Alternative Remedy Under PMLA Exists: Delhi High Court

Title: MS KRRISH REALTECH PVT LTD THROUGH ITS AUTHORISED REPRESENTATIVE v. UNION OF INDIA THROUGH SECERATARY MINISTRY OF FINANCE & ANR and other connected matters

Citation: 2025 LiveLaw (Del) 1437

The Delhi High Court has observed that the provisional attachment order (PAO) cannot be challenged in the writ jurisdiction when an alternative remedy is available under the Prevention of Money Laundering Act, 2002.

ED Search Under PMLA Not Restricted To Persons Named In Complaint, Covers Those In Possession Of Proceeds Of Crime: Delhi High Court

Title: DEPUTY DIRECTOR DIRECTORATE OF ENFORCEMENT v. AMLENDU PANDEY (D) THROUGH LR

Citation: 2025 LiveLaw (Del) 1565

The Delhi High Court clarified that Section 17 of the Prevention of Money Laundering Act (PMLA) does not restrict the Enforcement Directorate (ED) to conduct searches only at the premises of persons who have been named in the prosecution complaint.

Property From Illegal Cricket Betting Activities Constitutes 'Proceeds Of Crime', Can Be Attached By ED: Delhi High Court

Case title: Naresh Bansal & Ors. v. Adjudicating Authority And Anr (and batch)

Citation: 2025 LiveLaw (Del) 1590

The Delhi High Court has held that though cricket betting is not a separate predicate offence under Prevention of Money Laundering Act, 2002, the property generated from such illegal activities can be attached by the Enforcement Directorate.

SFIO Probe No Bar To PMLA Proceedings: Delhi High Court Upholds ED's Provisional Attachment In ₹6000 Cr Forex Scam

Case title: Sanjay Aggarwal v. Union Of India & Ors (and connected matters)

Citation: 2025 LiveLaw (Del) 1628

The Delhi High Court has made it clear that probe by Serious Fraud Investigation Office into the affairs of a company does not bar parallel proceedings under Prevention of Money Laundering Act.

FEMA Summons Governed By CPC, Not CrPC; ED Can Call Women To Office For Recording Their Statement: Delhi High Court

Title: SMT. POONAM GAHLLOT v. DIRECTORATE OF ENFORCEMENT

Citation: 2025 LiveLaw (Del) 1636

The Delhi High Court has held that the summons issued for discovery and production of evidence under the Foreign Exchange Management Act, 1999, are governed by Code of Civil Procedure and not Code of Criminal Procedure.

Non-Bailable Warrants Can't Be Issued Against Person Summoned As Witness Or Suspect During ED Probe: Delhi High Court

Case title: Sachin Dev Duggal v. Directorate Of Enforcement

Citation: 2025 LiveLaw (Del) 1777

The Delhi High Court has held that non-bailable warrants (NBWs) can't be issued against a person who has only been summoned as a witness or suspect in a money-laundering investigation, unless such person is shown to be accused of non-bailable offence.

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