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Only 313 Arrests Under PMLA In 20 Years; Strict Safeguards Are There : Solicitor General Tells Supreme Court
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Solicitor General of India Tushar Mehta on Wednesday urged that in view of the international conventions for tackling money laundering to which India is party, the consequent 'peer reviews' and the implications of non-compliance, the Supreme Court perhaps may not want to apply while deciding the validity of the PMLA the traditional standards which it employs in analysing the constitutionality...
Solicitor General of India Tushar Mehta on Wednesday urged that in view of the international conventions for tackling money laundering to which India is party, the consequent 'peer reviews' and the implications of non-compliance, the Supreme Court perhaps may not want to apply while deciding the validity of the PMLA the traditional standards which it employs in analysing the constitutionality of any other conventional statutes.
"There may be some leeway to the legislature if there is no violation of any fundamental rights", he prayed.
At the outset, the SG told the bench, "Your Lordships are dealing with a statute which is not just a penal statute but a preventive statute, a regulatory statute providing for investigation and final prosecution. There is a heavy responsibility that we the counsel appearing for the government carry with us. The responsibility I carry on behalf of the government of India is onerous because this Act is not a standalone Act which can be judged the way conventionally the honourable courts are judging penal statutes. The reason is that India is a part of a global anti-money-laundering network. Various conventions to which India is a party, India is a member, a signatory required all member states to bring their respective money laundering law in tune with each other because the global community found that money laundering is such a menace which cannot be tackled or treated at individual country level, it will have to be a global response. That gave several guidelines as to how the definition is to be framed, what should be the regime etc"
"Ultimately, that led to one body which is also mentioned in the preamble to the Act- the Financial Action Task Force- it is a body consisting of several countries and they give recommendations as to what should be done for the purpose of strengthening the money laundering regime of each country because the global community believes that if money laundering takes place, for example, in India, it affects the economy of other countries also, it has a cascading effect on other economies.
There is also a system whereby periodically an assessment takes place by the FATF, which is called peer review. All signatory nations would come and examine our regime, how India's regime is functioning, how its anti-money-laundering agencies are functioning, what is the legislative framework within which we are tackling money laundering. This is very, very crucial- they give gradings. These are the nations which are neither against India nor for India, it is neutral, our members also go as a part of assessing teams to other countries. Based on their examination of our design and enforcement regime, they give three grades- one is NC that is non-compliant, second is PC which is partially compliant and third is FC that is fully compliant. If particular parameters are not met, the resultant grading has international ramifications in terms of India's credit rating in terms of our capability of taking financial assistance from World Bank, Asian Development Bank etc. The way in which the entire architecture of the PMLA is structured is on the basis of that international global network and even the amendments, particularly section 3, are also made based upon the results of that assessment made by FATF", the SG continued to advance.
"Not only do we have to bring our law in consonance with this broad framework, but we would also be evaluated periodically. I will elaborate why we cannot as a nation afford to lag behind- the next evaluation is due in 2023. FATF conducts mutual evaluation of its members as regards the level of implementation of its recommendations on an ongoing basis. These are peer reviews where members of different countries assess another country. If any country has 'non-compliant' or 'partially compliant' rating for 8 or more recommendations, it is put in the 'Enhanced follow-up' immediately. There is the 'Grey list'. As of October 2021, 23 jurisdictions have been placed in the grey list for enhanced monitoring by FATF. These include Cambodia, Panama, Philippines, Pakistan, South Sudan among others. Pakistan got nominated in the grey list by FATF in June 2018 for serious deficiencies in compliance with FATF standards on terror financing and targeted financial sanctions", told the SG
"Then comes the black list, where there is enhanced due diligence against that country which all members will be doing. In most serious cases, countries are to apply counter measures to the ongoing money laundering, terrorist financing and proliferation financing risk emanating from the country. As of 21 February 2020, only two countries were in the FATF blacklist- that is, North Korea and Iraq. So complete financial sanctions are imposed. That country may have to then suffer trade deficit, inflation, devaluation of currency etc", submitted the SG
"Even though there may be no legal consequences, it means countries have failed to prevent international money laundering and terrorist financing. Though being greylisted does not imply economic sanctions per se, it serves as a signal to the global financing and banking system of the heightened risk of transactions with the country in question. On getting grey listed, the country's rating gets downgraded by global bodies which affects its position in the bonds or credit market, which then affects cross border capital flows as other countries look at it with speculation", he continued.
"But as an officer of the court, I must admit that that alone cannot be the ground for defending the validity of the statute. I will have to independently pass your lordships' muster that this is the Constitution of India-compliant", he added.
"We tried to find out international judgments to see if any court has tried to examine their respective money-laundering legislations in the context of this global network or not. Your lordships would be the first constitutional court in the world who would be examining the money laundering legislation from this perspective. Earlier also, in some High Court judgment, there is a stray reference to Vienna convention and FATF recommendations. But a reference to the entire architecture of the PMLA is not found anywhere", he continued.
Justice A. M. Khanwilkar asked, "How much value should be given to all this while considering constitutional validity? For interpretation of provisions, may be usefulness is there. But when we talk about constitutional validity, what are the fundamental rights? The protection under our Constitution is more relevant or the apprehension about undervaluing or underwriting by the countries?"
"It would be our fundamental rights, our constitutional principles which would ultimately be the decisive factor. There is no doubt about it", replied the SG
"Because even the conventions realise that fact", noted Justice Khanwilkar. Justice Dinesh Maheshwari said that the conventions repeatedly say that the party state would incorporate their provisions according to its domestic norms.
"The PMLA Act was amended to bring it in tune with the FATF recommendations after such assessment was made. If we failed to fulfil these recommendations or got that 8+, what will be the impact? And therefore if your lordships are satisfied that we made the provision or only amended the provision with a view to ensure that 8+ grading is maintained and if it otherwise does not contravene article 14, then your lordships may have a different look at it", replied the SG
Justice Khanwilkar asked, "do you want to link it with compelling necessity? All these conventions were there before the Parliament when the amendment was made or the laws were made?"
"The statements of objects and reasons of the Act and the amendments say so. Yes. The traditional standards which your lordships apply while analysing or deciding the validity of any other conventional statute, perhaps your lordships may not like to apply them while analysing the constitutional validity of this statute", responded the SG.
Justice Khanwilkar questioned, "The background facts are equally relevant to appreciate the purpose of this act which the Parliament has made. To that extent it is fine. But by striking it down, for being violative of fundamental rights, the consequences would be all that? Are you inviting us to go there?"
"I would not over-pitch it to that level. I bow down. I respectfully urge that if otherwise your lordships find that the measures the legislature has taken are taken with a view to implement the international obligations, then your lordships would give a little leeway to the legislation while examining the constitutional validity. If your lordships are examining the validity of say the food adulteration act, then it is completely domestic law, we are not a part of any global network, your lordships' parameters for examination may be different. Here, your lordships may give a little leeway to the legislature because it has its own implications. The role of the International Monetary Fund and World Bank also I have elaborated", replied the SG.
Justice Maheshwari asked, "So far as these ratings are concerned, after this assessment by FATF, has it been the case that we were found as a participating country to be lacking somewhere, and to cover up that we had to go for those amendments of 2013 etc?"
"Yes, that is my case", said the SG.
Justice Maheshwari observed, "That ultimately will also have to pass the master of constitutionality. Even if it is done, you will be allowed to do it only within the constitutional framework. So what we were indicating is that the consequence of grey listing may not be very relevant for our purposes"
"I absolutely bow down. It is only an interpretative guide for your Lordships to give a little leeway to the Parliament that they would be insightful while understanding the amendments that we have made. As to why we have amended the provisions in the way we have amended it, what was the object sought to be achieved, domestic object and international object would be different- food adulteration act, I would have different object to be achieved as the Parliament", replied the SG
Justice Maheshwari continued to observe, "Apart from the international implications coming up and evolving after 1988, even in other enactments, we have provided for dealing with ill gotten money or ill gotten gains one way or the other. So that affects the national economy also. So international obligations is only one part, but ultimately the overall picture will have to be taken"
"But ultimately in dealing with all the sections, your Lordships may bear this in mind that this legislative exercise is periodically undertaken...", the SG submitted.
Justice Khanwilkar noted, "All that you can say is that this is not an ordinary offence. This is a very special enactment and special offence created which is not only concerned with the domestic community but also international community"
"I could not put it better than that...But my submission is that Your lordships' examination from constitutional perspective may not be the same as while analysing any other conventional law which your lordships come across. There would be some leeway to the legislature if there is no violation of any fundamental rights", repeated the SG
Justice Khanwilkar remarked, "It is like terrorist crime at the international level. Therefore an offence which would end up in a punishment of only six months has been included in the money laundering law"
"That is the Deterrent effect to not take it lightly. Your lordships may apply a higher threshold considering the mischief it seeks to prevent, so far as article 14 argument is concerned. Terrorism, money laundering and drugs are the only 3 crimes which have received a global response. Money Laundering destroys the economy of more than one country. All other crimes are dealt with under domestic law. Here, Everybody is in sync with each other, and if you are not, then you are out of that net", stressed the SG.
"PMLA Act not a 'belagaam ghoda', Only 313 arrests in 20 years since the inception of the Act"- SG Tushar Mehta
The SG attempted to dispel the conception that the statute has become a 'belagaam ghoda' (unreigned horse) as Senior Advocate Kapil Sibal, for the petitioners, had said. "For the purpose of ensuring that nobody becomes a 'belagaam ghoda', we are expected to be strict by the global community and we are strict as a nation. As on date, 4700 cases have been investigated right from the inception till date by ED. The number of cases taken up for investigation each year in the last five years varies from 111 cases in 2015-16 to 981 in 2020-2021. This is the average number of cases. Very small number of cases are being taken up for investigation under the PMLA as compared to annual registration of cases under money laundering Acts in UK, USA, China, Austria, Hong Kong, Belgium and Russia, some of the major developing economies. This is just to satisfy your lordships' conscience that you are not dealing with anything that has become so harsh or over-encroaching upon the liberties of the citizens. Right from 2002, the year in which the PMLA act was enacted, till date, there are only 313 arrests in 20 years. The reason is very strict statutory safeguards", he told the bench.
At this, Justice A. M. Khanwilkar asked, "Only 313 arrests and more than 200 matters are pending here (connected to the instant petitions challenging the constitutionality of the PMLA; interim stay orders have been granted thereon)?"
"Your Lordships will be shocked to know that they are all cyclostyled kind of petitions, but the prayer for no coercive steps was so mechanically sought. Some of the people who have left the country after thousands of crores of money laundering and India is seeking their extradition, they filed petitions and prayed for and were granted orders of no coercive steps. They are staying outside, their affidavits are coming from other countries, they are opposing our extradition request. The total amount covered by your lordships' interim order is almost 67,000 crores. Because of no coercive action, what must have happened to the evidence disappearance is unimaginable. Now evidence disappears by the click of the button!", replied the SG.
"For a much larger country like India, it is pertinent to mention here that during last five years, that is 2016 to 2021, only 2186 cases are taken up for investigation. Out of 33 lakh predicate offences registered, ED has selected investigation in only 2186 cases in five years", he continued.
"There is a system in place for generation of reports of suspicious transactions. The chain which is used for money laundering, apart from Hawala operators, there might be fake companies, fictitious individuals, they might be doing operations of transfer etc. A sudden transaction of one crore in Jammu and Kashmir by any bank can be treated as suspicious transaction but the same amount transaction in Bombay may not be suspicious. There are internal guidelines and the banks are informed. So ED gets the correct information. If somebody deposits 50 lakh cash in Jammu and Kashmir, you will be informed by the bank. But in Bombay, even one crore would not do anything because it is common in several sectors. If somebody gives false information for us to act, he will be imprisoned. If one of my officers arrests without sufficient reason, he can be prosecuted and there is a one-year imprisonment. There are sufficient checks and balances so that power can never be misused. This is to satisfy your lordships' conscience on article 14", told the SG.
"If proceeds of crime are confiscated, by virtue of section 8 of the PMLA Act, it will go to the consolidated fund of India or to the legitimate owner. Only in 3 cases- Mehul Choksi, Nirav Modi and Vijay Mallya- the ED confiscated 18,000 crores by the order of the court following the procedure under sections 5, 6, 7, 8 and it was returned to the respective banks. The Act will have to be seen as a whole and not in pieces", prayed the SG.
Evolution of the PMLA statute in its present form from the 1988 Convention Against Illicit Traffic in NDPS to the Palermo Convention to the UN Convention Against Corruption
"There is an Interesting fact as to why the term money laundering is used. There is history behind it. In America, there was a mafia don called Al Capone. Whatever money he generated out of his criminal activities, he opened several laundries, 'Laundromat' as they call in America where you can yourself go and wash clothes yourself. There is no account if that laundry has received cash of $50 or $500. Nobody can find out. Suddenly the government found that the income of laundry business has skyrocketed and they went and investigated and found this is only a laundering of proceeds of crime", began the SG.
"It started off for drug money as it was drug money which was laundered. 'Determined to deprive persons engaged in illicit traffic (in NDPS) of the proceeds of their criminal activities and thereby eliminate their main incentive for so doing', the 1988 Convention said that Each Party shall adopt such measures as may be necessary to establish as criminal offences under its domestic law, when committed intentionally: The organisation, management or financing of any [drug trafficking] offences, and so on...So 'Intentionally' is an ingredient from the beginning. The argument of prejudice was that if a property is taken or purchased out of proceeds of crime and I am living there as a tenant, I would also be liable. No, unless I live there knowing that this is a part of criminal proceeds. But 'knowingly' is a part essential to constitute a criminal offence", advanced the SG.
Continuing, he advanced, "The second major breakthrough came in the year 2000 in what is known as the Palermo convention. Global community recognised the need to expand horizons of PML statutes beyond drug money and to all organised crimes of transnational nature. The Petitioners' perspective has been that the law was meant to tackle just drug money and nothing else. There is the United Nations convention against transnational organised crime, 2000. This is called the Palermo convention"
The SG continued to indicate that at the Opening of the Signing Conference for the said Convention, UN Secretary General Kofi Annan had made a speech from which the following is a extract- "...If crime crosses all borders, so must law enforcement.If the rule of law is undermined not only in one country, but in many, then those who defend it cannot limit themselves to purely national means.If the enemies of progress and human rights seek to exploit the openness and opportunities of globalization for their purposes, then we must exploit those very same factors to defend human rights, and defeat the forces of crime, corruption, and trafficking in human beings...Arrayed against these constructive forces, however, in ever greater numbers and with ever stronger weapons, are the forces of what I call uncivil society. They are terrorists, criminals, drug dealers, traffickers in people, and others who undo the good works of civil society.They take advantage of the open borders, free markets and technological advances that bring so many benefits to the world's people.They thrive in countries with weak laws and institutions.And they show no scruple about resorting to intimidation or violence.Their ruthlessness is the very antithesis of all we regard as civil.They are powerful, representing entrenched interests and the clout of a global enterprise worth billions of dollars.But they are not invincible"
"Kofi Annan, after this, was given the Nobel Peace prize", added the SG.
"The Palermo convention defines 'serious crime' as one where the maximum deprivation of liberty is for atleast 4 years or more. So it started with 4 years, but the tolerance to money laundering has reached such a low that now it is only 6 months. So if proceeds of crime are generated and there is money laundering, it is expected to be dealt with harshly...Palermo was also the first time when the definition of 'proceeds of crime' comes in, the first time the term 'predicate offence' is used. It says that 'Predicate offence' shall mean any offence as a result of which proceeds have been generated that may become the subject of an offence as defined in article 6 of this Convention. 'May become the subject of an offence'- so this is not merely an enactment which waits for the offence to take place and thereafter punishes the offender. It is prevention of money laundering act. Prevention is one of the main intent and objectives- Even if there is a property which may be used for money laundering. It is conceived for the first time in 2000 as 'predicate offence'", urged the SG.
Next, he took the bench to Article 6(1) of the convention that speaks of criminalisation of the laundering of proceeds of crime, which, he said, became our PMLA law- "'Concealment' even then was deemed to be part of the money laundering offence. Possession and use is also part of the offence if it is done knowingly. They are trying to be as strict as possible so that there is no incentive left. Somebody may purchase the property in my name and I occupy it saying that I have done nothing and that I am not a part of any criminal activity. But if I am using it or I am in possession knowing that it is proceeds of crime, then I am equally guilty. That is the global understanding of the problem"
"Further, Article 6(2) says that Each State Party shall seek to apply paragraph 1 of this article to the widest range of predicate offences. Some arguments were made by the petitioners regarding the list of scheduled offences to the PMLA, saying that 'look, copyright is there'. Prima facie, it sounds very funny that how can copyright act be a predicate offence. But we have seen the days when some of the terrorist money or crime money from Pakistan or Dubai from some of the notorious gangs used to be in pirated CDs and DVDs in Bombay running into thousands of crores. They used to come, pirated CDs and DVDs were distributed, but offence would be booked under copyright act. Copyright act may seem like how can you generate proceeds of crime under it? But the international response is that the widest range of predicate responses are to be added. Also, it says that all parties shall add all serious crimes, meaning 4 years plus, as predicate offences", continued the SG
"By way of measures for combating money laundering, the Palermo convention states that Each State Party Shall institute a comprehensive domestic regulatory and supervisory regime for banks and non-bank financial institutions and, where appropriate, other bodies particularly susceptible to money-laundering, within its competence, in order to deter and detect all forms of money-laundering. So the law is for deterring also and preventing the criminal act also. It is not just a post-offence Act. The Convention also says that Each State Party shall endeavour to ensure that any discretionary legal powers under its domestic law relating to the prosecution of persons for offences covered by this Convention are exercised to maximise the effectiveness of law enforcement measures in respect of those offences and with due regard to the need to deter the commission of such offences. So the PMLA law must have a Provision conferring discretion to prosecute in order to have a deterrent effect- that is the intent of the convention", he advanced.
The SG moved on to discuss the UN Convention against Corruption, where "the world community now recognises that Corruption is a major generator of proceeds of crime and money laundering and at least a major facilitator of proceeds of crime and money laundering". "Again Kofi Annan led the fight", said the SG.
"property, proceeds of crime, freezing/seizure, confiscate, predicate offence- all were defined. We have adopted the same definitions", he said.
Justice Khanwilkar asked, "Is there any indication about a provision such as section 45 of the PMLA Act (which stipulates rigorous conditions for bail) in any of these conventions?
Mr. Mehta replied, "It is there indirectly that whenever you are conferring discretion on the judicial authorities, it should be so conferred that it has a deterrent effect so as to maximise the implementation of the Act. That is traceable to section 45"
Justice Dinesh Maheshwari indicated Article 11(3) of the Palermo convention states that In the case of offences established in accordance with this Convention, each State Party shall take appropriate measures, in accordance with its domestic law and with due regard to the rights of the defence, to seek to ensure that conditions imposed in connection with decisions on release pending trial or appeal take into consideration the need to ensure the presence of the defendant at subsequent criminal proceedings. Further, the judge indicated Article 11(4) which says that Each State Party shall ensure that its courts or other competent authorities bear in mind the grave nature of the offences covered by this Convention when considering the eventuality of early release or parole of persons convicted of such offences
However, the judge added, "Ultimately everything will have to be examined on the touchstone of whether it is Constitution-compliant or not. But this is the genesis and since India is a party to all these conventions, naturally it would be adhering to as far as possible permissible in our framework"
[Section 3, PMLA] 'Not necessary to project proceeds of crime as untainted to constitute money laundering, mere possession enough'- SG Tushar Mehta
Justice Khanwilkar noted, "Section 3 of the PMLA has additional features- that you need to project and claim proceeds of crime as untainted money for the offence of money laundering to be complete. That is not the provision here (in the conventions"
"That is not here. That is a separate argument. It was never intended that it should be projected as untainted property", replied the SG
The judge continued to observed, "Because the entire argument of the petitioners was on that basis that mere possession is not enough, you have to project it and claim it as untainted money and only then the offence is complete"
"But that was never the intention. In fact, at the last assessment by the FATF, they asked who told you to keep this projection etc. We answered saying that it is not necessary, that it is one of the species of money laundering. We made a clarification, at the time of the amendment, that these are only illustrations, it is not a mandatory requirement for constituting the offence of money laundering. FATF has gone into it, we have gone into it, then the legislature has gone into it. We have cited judgments before FATF that in our jurisdiction, 'and' is read as 'or' and therefore, it is to be read as 'or projected as an untainted property'", replied the SG
Justice Khanwilkar said, "Their (petitioners') entire emphasis was this"
"They might not be having these details. But this main argument no longer holds good", said the SG
"It is a common sense argument that if concealment itself is a punishable offence, how can there be a requirement that you will project it as untainted? If I am concealing something, there is no question of my projecting anything as tainted or untainted. Concealment itself is an offence. They are in fact opposite to each other- If I am concealing, I can't project; if I am projecting, I cannot conceal", he added.
FATF recommendations and how various sections of PMLA adhere to the same
Advancing that the significance of the international conventions is in view of a periodic assessment of India by the FATF, the SG pointed out to the bench how the PMLA provisions and amendments comport to the recommendations of the FATF.
"The PML law is intended to be regulatory, preventive and penal. The FATF has recommended that the offence of money laundering should extend to any type of property, regardless of its value, that directly or indirectly represents the proceeds of crime. When proving that property is the proceeds of crime, it should not be necessary that a person be convicted of a predicate offence. So suppose we come in possession of some material by which it becomes clear that there has been a criminal activity, then under the provisions of section 66(2) of the PMLA, we immediately intimate the other enforcement agencies- it can be income tax, local police, CBI- that this is what we have found out during our investigation but this is a predicate offence and you now start investigation", began the SG.
"When your lordships are presented with the fact that the ECIR is not served on the accused, what the scheme of the Act is that if we serve the ECIR immediately, the person would know that I will have to with the click of the button destroy the evidence. So the scheme is that whenever any action prejudicial to the interest of the delinquent is taken by the authorities, the attachment under section 5, arrest under section 19 or whatever action, at that stage, there are three major requirements- it can be done only by the authorities defined in the Act, and that it must be done with reasons to be recorded which satisfy such authority of the belief of the existence of the circumstances for invoking section 5 or section 19 etc. The scheme is unlike FIR. When FIR is registered, the police intimate the magistrate and give a copy to the accused. That is categorically not provided here because we have a process to identify assets without prior notification to the owner", he continued.
Justice Khanwilkar commented, "To take by surprise?"
"Yes. Otherwise, we will get nothing. In most of these cases before your lordships, unfortunately the evidence would have been lost. Now people go and buy citizenship of certain countries, certain islands, which are not a signatory to the treaty and so these persons cannot be brought back. So these are the broad recommendations", replied the SG
In so far as the reversal of the burden of proof in the PMLA Act was raised as a ground for its unconstitutionality by the petitioners, the SG pointed out that the FATF recommends that every country must ensure that the intent and knowledge required to prove the offence of money laundering may be inferred from objective factual circumstances. "The Scheme of the PMLA Act provides that you will have to arrive at the objective satisfaction that the set of facts arise and then the burden shifts", he explained.
The SG indicated the FATF's recommendation that where countries apply a threshold approach, predicate offence should at a minimum comprise of all offences which fall within the category of serious offences under the national law or should include offences punishable by a maximum penalty of more than one year imprisonment. "So the four years is now one year- the tolerance level of the global community against money laundering is getting low. It has become 6 months also (for those countries that have a minimum threshold for offences in their legal system)", said the SG.
In so far as the FATF recommended that it is not necessary that a person should first be convicted for a predicate offence, the SG advanced, "Money laundering is a standalone offence. For example, I am being investigated under prevention of corruption act. I am found with 50 crores of cash. Ultimately I get a discharge on the ground that I am not a public servant therefore PC act which is the predicate offence does not apply. Then money laundering offences still continues. Sometimes the offence is unable to be successfully brought to the doorstep of the accused. But we are in possession of the material showing money-laundering, maybe not at the behest of the accused A and B who were acquitted, but we will continue with our investigation and when we come to know under section 66(2), we will intimate the statutory authorities namely local police or who ever is the agency that now we have found out the real culprit."
As regards the FATF recommendation that there should be appropriate ancillary offences to the offence of money laundering including participation in, association with or conspiracy to commit, attempting and abetting, facilitating and counselling the commission, the SG submitted, "So anything to do with money laundering is to be criminalised. And there has to be provided the widest range of predicate offences."
"Environmental law offences are one of the major sources of money laundering. I have a huge factory, I have 500 crores as my STP processing unit and my disposable waste goes directly into this. That 500 I will launder thereafter. It was argued on the other side how environmental law can be money laundering...the Dawood gang used to invest heavily in pirated CDs and DVDs and thousands of crores were being laundered and the only predicate offence would be booking under the violation of copyright act. There was an argument on the other side that it is absurd that copyright act has been added in the schedule to the PMLA Act", the SG advanced.
Case : Vijay Madanlal Choudhury and others vs Union of India and others Special Leave to Appeal (Crl.) No(s). 4634/2014 and connected cases
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