1.1 The Prevention of Money Laundering Act, 2002 (PMLA) is among the very few statutes which was brought into force in terms of the mandate of the United Nations read with other international Conventions. The object behind the Act which is brought in to support global Anti-Money Laundering regime (AML) is to confiscate the proceeds of crime generated out of scheduled/predicate offences, which are laundered to project such proceeds as untainted income. The object of the Act is achieved by way of a two pronged approach. The first one, which is a kind of civil proceedings relates to identification of proceeds of crime, provisional attachment, confirmation and later on confiscation of such proceeds of crime after the person concerned is convicted for money laundering offence under the Act. The second proceeding relates to prosecution of the accused before the trial court for the money laundering offence. The scope of this article is to analyse the provisions relating to the provisions relating attachment of properties, also known as ‘proceeds of crime’ by the authorities concerned, especially after the amendment in PMLA during 2015 and 2018 by introducing a new concept of ‘value equivalent’ attachment/confiscation of proceeds of crime.
2. Confiscations of profits of crime
2.1 Internationally the AML regime was brought after sustained efforts by UN and other regional Conventions, to deprive criminals the proceeds of crime (referred in some jurisdictions as “profits of crime”) which are laundered and subsequently re-injected into legitimate economy. Confiscation of proceeds of crime is an essential and indispensable implement in the hands of the State, as majority of crimes are profit driven, and seizure and confiscation of such illicit gains would definitely hamper the very existence and growth of criminals and criminal syndicate. Confiscation of assets or property, in certain jurisdictions also referred as “forfeiture” would mean permanent deprivation of property by an order of the court or competent authority. The terms ‘forfeiture’ and ‘confiscation’ are terms which are often used interchangeably. Forfeiture takes place through a judicial or administrative procedure established in law by which the ownership of specified funds or assets are transferred to the State.
2.2 Initially under criminal law jurisdiction, the States were confined to confiscation of instrumentalities of crime, that is, the instruments that were used in the perpetration of crime for example, a car or a boat used to transport narcotics. Later on the strategy shifted to confiscation of proceeds of crime that is, the financial gains obtained through criminal activities sometimes referred to as fructum seleris or productum seleris. Among various types of confiscation, two are important from the point of view of AML regime, object confiscation and value confiscation. Object confiscation is also known as forfeiture of instrumentalities of the crime. Value confiscation provides a better legal model for depriving the offenders of their ill gotten gains in that it is not restricted to the property which constitutes proceeds of crime but rather departs from an evaluation of these proceeds. Another distinct advantage of value confiscation over object confiscation is that it makes it possible to avoid the same proceeds being confiscated more than once. Another view of value-based confiscation by certain authors is that such a method of confiscation empowers a Court to determine the benefit accruing to an accused by way of criminal conduct, and impose a pecuniary liability (fine) which will be in multiples of profit derived from the crime, which is realizable against any asset of such accused.
2.3 Value-based confiscation allows for the value of proceeds and instrumentalities of crime to be determined and assets of an equivalent value to be confiscated by the competent court. It is done on the basis of the civil court’s standard of proof which is frequently lower than the standard of proof required for criminal conviction. Under this method the Court determines the value of benefit realised from a crime and pronounces a judgment allowing the State to enforce it against the person concerned.
2.4 The clearest advantage of value confiscation lies in the fact that unlike object confiscation it operates in personam meaning that confiscation in principle be pronounced only with regard to the proceeds enjoyed by the offender and can also be enforced on the property owned by the offender. The rights of bona fide third parties established after the offence has been committed can in principle not be affected by value confiscation. The major drawback being it can be circumvented by transferring property to third parties such as family members, associates or juristic persons. Because of this fact value confiscation can also be enforced on legally acquired property.
3. Proceeds of crime under PMLA regime
3.1 Section 3 of the Prevention of Money Laundering Act, 2002 (PMLA) defines the term “offence of money laundering” which is punishable under Section 4. Apart from punishment with fine, for the offence of money laundering as per the procedure established under Sections 44 and 45 of the Act, the Act also empowers the authorities to provisionally attach properties involved in money laundering and such attachment upon confirmation (in adjudicatory civil proceedings under the Act) shall remain so till the conclusion of trial of money laundering offence. The offence of money laundering under Section 3 centers around laundering ‘proceeds of crime’ [as defined under Section 2(1)(u)] and hence this term assumes importance for any proceeding under the Act. The Act further provides that the proceeds of crime shall arise out of scheduled offence which is listed as per Section 2(1)(y) or criminal activity relating to such scheduled offence. In other words the proceeds of crime attributable to scheduled offences listed under the Act, are liable for seizure, freezing, attachment, confirmation and confiscation under the Act. The term “proceeds of crime” which is defined under Section 2 (1)(u) of the Act, has undergone changes from its inception, especially in the years 2015 , 2018 and 2019, as noted below.
3.2.1 Section 2 (1)(u) – Statutory provision -1.7.2005
“Proceeds of crime” means any property derived or obtained, directly or indirectly, by any person as a result of criminal activity relating to a scheduled offence or the value of any such property.
3.2.2 Amended by Finance Act, 2015 w.e.f 1.4.2015 (in italics)
“Proceeds of crime” means any property derived or obtained, directly or indirectly, by any person as a result of criminal activity relating to a scheduled offence or the value of any such property, or where such property is taken or held outside the country, then the property equivalent in value held within the country.
3.2.3 Amended by Finance Act, 2018 w.e.f 19.4.2018 (in italics)
“Proceeds of crime” means any property derived or obtained, directly or indirectly, by any person as a result of criminal activity relating to a scheduled offence or the value of any such property, or where such property is taken or held outside the country, then the property equivalent in value held within the country or abroad.
3.2.4 Explanation to Section 2(1)(u) inserted by Finance Act, 2019 w.e.f 1.8.2019
Explanation.– For the removable of doubts, it is hereby clarified that “proceeds of crime” including property not only derived or obtained from the scheduled offence but also any property which may directly or indirectly be derived or obtained as a result of any criminal activity relatable to scheduled offence;
3.3 The term ‘property’ is defined under Section 2 (1)(v) of the Act which has to read with Section 2 (1)(u). However contentious issues have only arisen on interpretation of Section 2 (1)(u) which are analysed below. The definition of the term “property” has undergone change only once during the year 2013, and the same is reproduced below.
3.3.1 Section 2 (1)(v) – Property – w.e.f. 1.7.2005
“Property” means any property or assets of every description, whether corporeal or incorporeal, movable or immovable, tangible or intangible, and includes deeds and instruments evidencing title to, or interest in, such property or assets wherever located;
Explanation inserted w.e.f 15.2.2013
Explanation. – For the removal of doubts, it is hereby clarified that the term ‘ property’ includes property of any kind used in the commission of an offence under the Act or any of the scheduled offence;
3.4 The definition under Section 2(1)(u) is to be read with Section 2(1)(v) which defines ‘property’ to mean any property or assets of every description, whether corporeal or incorporeal, moveable or immoveable, tangible or intangible including title to or interest in such a property and their assets, wherever located. The Explanation to Section 2(1)(v) defines property to mean property of any kind used in the commission of an offence under the PMLA itself or of any scheduled offence.
3.5 A plain reading of Section 2(1)(u) would signify that there are three limbs within the definition. They are (a) any property derived/obtained by a person as result of criminal activity relating to scheduled offence, (b) value of any such property OR (c) where such property is taken or held outside country, then the property of equivalent value held within the country. The crux of the issue is the amendment in 2015 and 2018 especially relating to the words ’value of such property’ The definition of “proceeds of crime” in PMLA was amended in 2015 to include “property equivalent held within the country” in case proceeds of crime is taken out or held “outside the country”. The present amendment shall allow to proceed against property equivalent to proceeds to crime held outside the country also. Intention of the legislature to bring in the ambit of Section 2(1)(u) to the properties held abroad has been explained by the PIB release, which otherwise also is clear and not a contentious issue. The issue which is under bone of contention is the properties available in India especially untainted or legitimate property, whether would fall under the ambit of ‘value equivalent’, or to be precise what is the scope and extent of this term.
3.6 The inclusive definition of “proceeds of crime” respecting property of the second abovementioned nature – i.e. “the value of any such property” – gives rise to potential multi-layered conflicts between the person suspected of money-laundering (the accused), a third party (with whom such accused may have entered into some transaction vis-a-vis the property in question) and the enforcement authority (the State) . Before analysing the provisions of the Act the important questions which are the subject- matter of dispute presently and also in future can be summarised as follows:
(a) What is the legislative intent behind introducing ‘value equivalent’ concept under Section 2 (1)(u)?
(b) Whether under ‘value equivalent’ properties acquired out of legitimate income be attached?
(c) Whether properties which have no nexus or link to the alleged scheduled offence or money laundering offence be attached paving way for a “retrospective application” of the statute?
(d) Whether value equivalent attachment can be resorted if the proceeds of crime is siphoned off or untraceable?
3.7 In K. Rethinam v. Union of India the Delhi High Court had occasion to deal with the aspect of ‘value equivalent’ among other issues challenged. The High Court held that,
“48.….The expression value of any such property’ would be a value equivalent to the value of a property derived or obtained directly or indirectly by any person as a result of criminal activity. The property itself may no longer be available but the equivalent value of such a property, whether held in cash, etc., would be available for attachment.”
3.8 In the above case while dealing on the expression ‘value equivalent’ the High Court held as follows:
“45….The Court first would like dwell on the definition of proceeds of crime’ under Section 2 (1)(u) of the PMLA. It is defined to mean:
(a) any property derived or obtained, directly or indirectly, by any person; as a result of criminal activity relating to a scheduled offence, or
(b) the value of any such property, or
(c) where such property is taken or held outside the country, then the property equivalent in value held within the country.
46. It was contended by petitioners that to attract (b) the property which is the proceeds of crime should be taken out of or held outside the country and not be available in the country.
47. The above submissions ignore the important disjunctive ‘or’ occurring between the expression ‘the value of any such property’ in (b) above and the expression in (c) where such a property is taken or held outside the country. On the contrary, the qualifying word ‘such’ in (b) refers to the earlier portion in (a) viz. ‘property derived or obtained, directly or indirectly, by any person’ as a result of criminal activity relating to a scheduled offence.”
3.9 However the Delhi High Court in a subsequent judgment in Directorate of Enforcement v. Axis Bank supra analysed the concept differently. While examining the three situations envisaged under Section 2(1)(u) differently. The High Court observed that: (SCC Online paras 106 & 107)
“106. Among the three kinds of attachable properties mentioned above, the first may be referred to, for sake of convenience, as “tainted property” inasmuch as there would assumedly be evidence to prima facie show that the source of (or consideration for) its acquisition is the product of specified crime, the essence of “money laundering” being its projection as “untainted property” ( Section 3)….
107. … For the sake of convenience, the properties covered by the second and third categories may be referred to as “the alternative attachable property” or “deemed tainted property”. 
The High Court further held that: (Axis Bank case, SCC Online para 110)
“110….Thus, it must be observed that, in the opinion of this Court, if the enforcement authority under PMLA has not been able to trace the “tainted property” which was acquired or obtained by criminal activity relating to the scheduled offence for money laundering, it can legitimately proceed to attach some other property of the accused, by tapping the second (or third) above-mentioned kind provided that it is of value near or equivalent to the proceeds of crime…” 
In the above judgment the High Court gave a new dimension to the 2nd and 3rd limb of definition by created a legal fiction ‘deemed tainted property’. Therefore whether by taking a cue from the judgment whether the authorities are correct in attaching untainted or legitimate properties as an alternative to the alleged proceeds of crime which were neither traceable, due to factors such as paucity of time, inability to identify, siphoned off and similar other factors. If so whether such an action is in tune with the provisions of PMLA and in consonance with international conventions under AML regime are issues which are likely to crop up. However, while interpreting the provisions the High Court further elucidated the issue by way of caution to the authorities concerned, with the following observations. The High Court observed that: (Axis Bank case, SCC Online para 160)
“160….but, in cases where the enforcement authority seeks to attach other properties, suspecting them to be “proceeds of crime”, not on the basis of fact that they are actually “derived or obtained” from criminal activity but because they are of equivalent “value” as to the proceeds of crime which cannot be traced, it is essential that there be some nexus or link between such property on one hand and the person accused of or charged with the offence of money-laundering on the other…” 
3.10 Earlier while analysing the words ‘such property’ used in Section 2(1)(u) the High Court in Axis Bank case held as follows:
“109…Since the second of the above species of “proceeds of crime” uses the expression “such property”, the qualifying word being “such”, it is vivid that the “property” referred to here is equivalent to the one indicated by the first kind. The only difference is that it is not the same property as of the first kind, it having been picked up from among other properties of the accused, the intent of the legislature being that it must be of the same “value” as the former. Though these words are not used in the second category, it is clear that the said kind also has to be understood in the same sense.”
3.11 FATF in their Recommendations in 1996 reiterated the suggestion for legislative measures to be adopted for confiscation of such assets or “property of corresponding value“, cautioning that such measures be “without prejudicing the rights of bona fide third parties“. The definitions of proceeds of crime and property in the PMLA are broad enough to allow for confiscation of property derived directly or indirectly from proceeds of crime relating to a scheduled (predicate) offence, including income, profits and other benefits from the proceeds of crime. These definitions also allow for value confiscation, regardless of whether the property is held or owned by a criminal or a third party. As Section 65 of the PMLA refers to the rules in CrPC, instrumentalities and intended instrumentalities can be confiscated in accordance with Sections 102 and 451 CrPC.
3.12 The High Court in Axis Bank case summed up the meaning of ‘value equivalent’ as follows: (SCC Online para 171)
“171. (iv)If the “tainted property” respecting which there is evidence available to show the same to have been derived or obtained as a result of criminal activity relating to a scheduled offence is not traceable, or the same for some reason cannot be reached, or to the extent found is deficient, the empowered enforcement officer may attach any other asset (“the alternative attachable property” or “deemed tainted property“) of the person accused of (or charged with) offence of money-laundering provided it is near or equivalent in value to the former, the order of confiscation being restricted to take over by the government of illicit gains of crime.
The concept of deemed tainted property or alternative attachable property is a new and evolving jurisprudence. However looking at it from the rationale behind depriving the criminals from the proceeds of crime generated out of criminal activity, if such proceeds of crime are untraceable, siphoned off, found short, due to laundering and mingling with legitimate income or due to other reasons, and when the person concerned is found guilty of scheduled offence and money laundering offence the State’s action to recover such proceeds of crime by applying fall back option of alternative attachable property as visualised in Axis Bank case above, is a viable option with the Government. However, such attachment would be subject to projecting the rights of bona fide third parties, as cautioned by Delhi High Court in the following words: (SCC Online para 171)
“171…(xiv) If it is shown by cogent evidence by the bona fide third party claimant (as aforesaid), staking interest in an alternative attachable property (or deemed tainted property) claiming that it had acquired the same at a time anterior to the commission of the proscribed criminal activity, the property to the extent of such interest of the third party will not be subjected to confiscation so long as the charge or encumbrance of such third party subsists, the attachment under PMLA being valid or operative subject to satisfaction of the charge or encumbrance of such third party and restricted to such part of the value of the property as is in excess of the claim of the said third party. 
The FATF during 2003 noted that countries may adopt legislative measures to confiscate the proceeds of property laundered from either predicate or money laundering offence including instrumentalities and property of corresponding value, without prejudicing the rights of bona fide third parties.
3.13 However the Delhi High Court in Axis Bank case observed that if the deemed tainted property or alternative property belongs to bona fide third party who has acquired the same for bona fide and lawful consideration can approach the Adjudicating Authority for release of such property attached. In fact earlier in Indian Bank case the Madras High Court held that PMLA does not take care of the victims of money laundering especially bona fide third parties, such as banks who as secured creditors have mortgage right over properties attached under PMLA. Taking into consideration a lacuna prevailing in the legislation, as a benevolent measure the legislature brought in immediately appropriate provision under PMLA by inserting Section 8(8) by the Finance Act, 2015, w.e.f. 14.5.2015 of the PMLA enabling a claimant of property who has legitimate interest in the property or suffered quantifiable loss, to approach the Special Court for restoration of the property after trial or during the trial.
3.14 The Delhi High Court in yet another reported judgment held that value equivalent concept is to be applied only if property is held outside India. While interpreting Section 2(1)(u) the High Court held as follows: (SCC Online para 108)
“108.The second part of the definition of the expression proceeds of crime includes within its ambit, a property equivalent to the value of the property, which is derived from any criminal activity and is held outside the country. In other words, if any property that is derived or obtained from any criminal activity relating to a scheduled offence is held outside India, then a property of an equivalent value held in India, would also fall within the scope of expression of proceeds of crime.”
3.15 The Appellate Tribunal, PMLA has an occasion to examine this issue in Surendra Singh v. DoE. It was held as follows:
“… “Value” as defined in Section2(zb) of the PMLA has to be harmoniously read with Section 2(u) of the Act which mandates to acquisition value only to situations where the proceeds of crime being attached. Such application cannot be pedantically extended to situations where the property equivalent of alleged proceeds of crime are being attached, which do not have any nexus or continuum with the alleged direct proceeds of crime. The said exercise can only be done if ED is not in a position to recover the actual amount of proceeds of crime from the accused who by manipulation spent the proceeds of crime and the ED is not able to recover the same and attached that only under those circumstances, the property can be attached equivalent to value thereof if the party has some link and nexus in the crime or the attached property was purchased from proceed of crime and is in possession of third party.”
3.16 In another case, the Appellate Tribunal, PMLA held that:
“….The legislature has consciously used the words ‘value of any such property’ and “property equivalent in value” in the same definition clause and therefore, they cannot connote or mean as the same property. Therefore, when the case of the ED falls under equivalent in “value of any such property”, it cannot take any unrelated property which has no nexus or link with the actual proceeds of crime and attach the same as “property equivalent in value” in the absence of evidence.”
3.17 In a latest judgment the Division Bench of the Punjab & Haryana High Court in Seema Garg v. Directorate of Enforcement had occasion to examine the concept of ‘value equivalent’ attachment as one of the issues framed during the course of disposing writ petitions filed under Section 42 of the Act, challenging the confirmation of provisional attachment of properties, confirmed by the Appellate Tribunal. The P&H High Court observed that:
“….There are three limbs of Section 2(1)(u) of the PMLA, namely, (i) Any property derived or obtained directly or indirectly as a result of criminal activity relating to scheduled offence; (ii) Value of property derived or obtained from criminal activity; (iii) Property equivalent in value held in India or outside where property obtained or derived from criminal activity is taken or held outside the country. …….The first limb deals with property directly or indirectly obtained from criminal activity. The third limb is applicable where property obtained from criminal activity is held or taken outside India. In case property derived/obtained from criminal activity is held or taken outside India, property of equivalent value held in India or abroad would be proceeds of crime. The second limb, which is the core issue involved in present appeals covers ‘value of property’ derived/obtained from criminal activity. The third limb of definition clause was inserted by Act 20 of 2015. The aforesaid 3rd limb has been further amended w.e.f. 19.04.2018 by further enlarging the scope. The question arises that if phrases ‘value of such property’ and ‘property equivalent in value held within the country or abroad’ are of same connotation and carry same meaning, there was no need to insert third limb in the definition of ‘proceeds of crime’. Accordingly, words ‘value of such property’ and ‘property equivalent in value held within the country or abroad’ cannot be given same meaning and effect. Had there been intention of legislature to include any property in the hands of any person within the ambit of proceeds of crime, there was no need to make three limbs of definition of proceeds of crime” 
3.18 The High Court after examining the issue with reference to other provisions under the Act held as follows:
“ …The moot question arises that whether property of equivalent value may be attached where property derived or obtained from scheduled offence is not held or taken outside India. If any property is permitted or held liable to be attached irrespective of its date of purchase, it would amount to declaring second and third limbs of definition of ‘proceeds of crime’ one and the same. The amendment made by legislature cannot be meaningless or without reasons. Use of different words and insertion of third limb in the definition cannot be ignored or interpreted casually. In our considered opinion, to understand the true meaning of the second limb of definition of ‘proceeds of crime’, it must be read in conjunction with Sections 3 and 8 of the PMLA. If all these sections are read together, phrase ‘value of such property’ does not mean and include any property which has no link direct or indirect with the property derived or obtained from commission of scheduled offence i.e. the alleged criminal activity.”
3.19 The P&H High Court in the above judgment observed that many scheduled offences under different enactments listed under the Act do not involve property like for example, offences under the Wildlife Act, waging a war against animals, but still the offences are punishable under the Act. The High Court concluded with the finding “… object of the Act is not defeated merely on the ground that property derived from crime is not available for attachment. The property derived from legitimate source cannot be attached on the ground that property derived from scheduled offence is not available.”
3.20 The Division Bench judgment in Seema Garg has taken a decision different from that of Axis Bank case, holding that property derived from legitimate source cannot be attached if the property derived from scheduled offence is not traceable setting into motion a new jurisprudence in the PMA regime. The Axis Bank case judgment allows attachment of properties derived from legitimate sources if the alleged proceeds of crime are not traceable, cannot be found or found short.
4. Similar Provisions under FEMA 1999
4.1 It is pertinent to point that similar provision Section 37-A of FEMA 1999 was inserted by the Finance Act, 2015 with effect from 14th May 2015, providing for value equivalent seizure, attachment and confiscation, which reads as follows:
“37-A. Special provisions relating to assets held outside India in contravention of Section 4. –(1) Upon receipt of any information or otherwise, if the Authorised Officer prescribed by the Central Government has reason to believe that any foreign exchange, foreign security, or any immovable property, situated outside India, is suspected to have been held in contravention of Section 4, he may after recording the reasons in writing, by an order, seize value equivalent, situated within India, of such foreign exchange, foreign security or immovable property:
Provided that no such seizure shall be made in case where the aggregate value of such foreign exchange, foreign security or any immovable property, situated outside India, is less than the value as may be prescribed.”
4.2 While the value equivalent concept was introduced under PMLA during 2015, at the same time similar provisions were introduced under the Foreign Exchange Management Act, 1999 (FEMA 1999) The newly inserted Section 37-A of FEMA empowers the authority to seize value equivalent of property of the person accused in India if the foreign exchange, foreign security or immovable property located outside India, is held in contravention of Section 4 of FEMA 1999. The purpose of bringing this provision is that due to confidentiality reasons even the details of monies deposited by person accused in countries abroad is not forth coming from bank authorities including those in tax havens, and in the absence of even basic information sharing the question of tracing, seizing and confiscation of monies deposited abroad is an impossible task for the investigating agencies. Therefore, the provision was inserted to pave way for value equivalent seizure in India. The provisions under FEMA makes it clear without any ambiguity that it applies only in cases where foreign exchange, immovable property, etc is held abroad.
While examining the issue on hand, it has come to the author’s notice that very few reported judgments have dealt with the subject-matter and the jurisprudence is evolving, as the PMLA is a special enactment. As observed by the High Court (Seema Garg) definition clause in a statue cannot be read in isolation and it should be examined in the light of other sections which creates rights and liabilities. Therefore, to examine the legislative intent of inserting ‘value equivalent’ the related provisions of PMLA have to be examined. Attachment of legitimate properties under value equivalent concept leads to application of the Act retrospectively to the properties acquired decades earlier. Further immediately after filing an ECIR and commencement of investigation, the authorities would only have prima facie estimate of PoC (as available in the FIR of the scheduled offence) which may be more or may be less. When the scheduled offence in most cases is still under FIR stage and charges are yet to be framed the alleged PoC will itself be a tentative estimate and while so, if attachment of legitimate properties under ‘deemed tainted properties’ would lead to arbitrary usage of power vested under Section 5. Further, the person accused of committing the scheduled offence would not be giving details of PoC in a platter, and the same can be obtained by sustained investigation with the help of incriminating records seized, if any. In the absence of the same if the authority choses to merely attach the extent of estimated PoC by taking recourse to value equivalent or part of value equivalent PoC, such an action would go against the AML regime.
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* Advocate. Author practices in Indirect Tax litigation and specialises in Anti-Money Laundering laws.
 Manual On International Co-Operation For the Purpose of Confiscation of Proceeds of Crime – United Nations (UNODC) September 2012) UNODC
 Guy Stessens “Money Laundering – A New Law Enforcement Model”, Cambridge University Press (2000)
 Supra note 2
 Supra note 3
 Directorate of Enforcement v. Axis Bank, 2019 SCC OnLine Del 7854
 Mutual Evaluation Report – AML & Combating the financing of terrorism – FATF – June 2010
 Directorate of Enforcement v. Axis Bank, 2019 SCC OnLine Del 7854
 OECD, Confiscation of instrumentalities and proceeds of corruption crimes in Eastern Europe and Central Asia https://www.oecd.org/corruption/acn/OECD-Confiscation-of-Proceeds-of-Corruption-Crimes-ENG.pdf
 Indian Bank v. Government ofIndia, Directorate of Enforcement, 2012 SCC OnLine Mad 2526
 Abdullah Ali Balsharaf v. Directorate of Enforcement , 2019 SCC OnLine Del 6428
 Surendra Singh v. Directorate of Enforcement , FPA/PMLA/1928/HYD/2017, judgment dated 21st Dec 2018
 Omar Ali Obaid v. Directorate of Enforcement, FPA/PMLA/2617/DLI/2018, judgment dated 29th August 2019
 Seema Garg v. Directorate of Enforcement, order dated 6.3.2020
 Directorate of Enforcement v. Axis Bank, 2019 SCC OnLine Del 7854
 Seema Garg v. Directorate of Enforcement, order dated 6.3.2020