This White Collar Crimes Roundup of July 2025 provides an overview of significant cases that made headlines this month, such as the Supreme Court’s relief on M3M Group in a PMLA case, the ATFP’s confirmation of asset attachment in the PNB fraud and ICICI-Videocon loan cases, SEBI’s action against JS Group and Cressanda promoters, along with key High Court ruling including Delhi High Court’s stance on piercing the corporate veil, Bombay High Court’s observation on dynamically interpreting IPC offences under PMLA, and Kerala High Court’s denial of bail in the Chinese Loan App money laundering case.
HIGHLIGHT OF THE MONTH
APPELLATE TRIBUNAL FOR FORFEITED PROPERTY (ATFP) | PNB Fraud Case | ATFP upholds attachment of Nirav Modi’s aide’s New York property worth $ 7.1 million by ED
The bench of G.C Mishra and Rajesh Malhotra* (Members) were called upon to consider the appeal wherein the wife of one of the co-accused of PNB Fraud case, challenged the decision of Adjudicating Authority, whereby it confirmed the attachment of their New York based flat by the Enforcement Directorate (ED). The Tribunal dismissed the appeal stating that, as per definition of Proceeds of Crime (POC) under Section 2 (1)(u) of the PMLA, 2002, the legislation entitles the attachment of proceeds of crime which are either generated as a result of criminal activity relating to a scheduled offence, or, the equivalent value, or, where such proceeds of crime is taken, or, held outside the country, then the property equivalent in value held within the country or abroad.
[Rakhi Bhansali v. Deputy Director, Directorate of Enforcement, FPA-PMLA-3021/MUM/2019] Read more HERE
BANK AND FINANCIAL FRAUD
SUPREME COURT | Multi Crore Chit Fund Scam Case | Read why Supreme Court granted interim relief from arrest to actor Shreyas Talpade
In a writ petition filed by actor and filmmaker Shreyas Talpade in connection with a series of FIRs lodged across multiple States alleging his involvement in a multi-crore investment fraud linked to the SAGA Group and its affiliated cooperative societies, the division bench of B.V. Nagarathna and K.V.Viswanathan, JJ. issued notice to the State authorities concerned and directed that Shreyas be protected from arrest pending further consideration of the matter.
[Shreyas Talpade v. State of Haryana, 2025 SCC OnLine SC 1505] Read more HERE
APPELLATE TRIBUNAL FOR FORFEITED PROPERTY | Appellate Tribunal for Forfeited Property confirms attachment of Chanda Kochhar’s assets in ICICI-Videocon Loan case
In an appeal filed by Enforcement Directorate (‘ED’) challenging the Adjudicating Authority’s order dated 6-11-2020, wherein the authority refused to confirm attachment of a flat in Churchgate, Mumbai (‘the Flat’) and cash of Rs.10.5 Lakhs, the Bench of Munishwar Nath Bhandari, J. (Chairman) and Balesh Kumar (Member) found a clear chain of events indicating money laundering, including a Rs 64 crore transfer from Videocon to NRPL, a company controlled by Chanda Kochar’s husband. The long-standing association and financial interlinking between Chanda Kochhar’s husband and Videocon justified the attachment of property purchased with diverted funds. Thus, setting aside the Adjudicating Authority’s order, except for the attachment of Rs 10.5 lakhs, which was not confirmed, the Tribunal upheld all other parts of the Provisional Attachment Order dated 10-1-2020.
[Enforcement Directorate v. Chanda Kochhar, FPA-PMLA-3802/DLI/2020] Read more HERE
DELHI HIGH COURT | Delhi High Court grants bail to Chief Business Strategy Officer of IL&FS Securities Services Ltd. in Dalmia Cements fraud case
In a bail application filed by the Head of the Business Department and the Chief Business Strategy Officer (‘the Officer’) of the IL & FS Securities Services Ltd. (‘ISSL’) under Section 439 of the Code of Criminal Procedure, 19731 (‘CrPC’) to seek regular bail in connection to a First Information Report (‘FIR’) registered under Sections 420/409/467/471/120-B/34 of the Penal Code, 18602 (‘IPC’), a Single Judge Bench of Vikas Mahajan, J. noted that the custody of the Officer was no longer required and hence granted him regular bail.
[V. Hansprakash v. State (NCT of Delhi), 2024 SCC OnLine Del 5524] Read more HERE
PMLA, APPELLATE TRIBUNAL, NEW DELHI | [2005 IPO Scam] PMLA Appellate Tribunal confirms provisional attachment of Karvy Consultant’s FDR of Rs 65 lakh.
Prevention of Money Laundering Act, Appellate Tribunal, New Delhi: An appeal was filed by Karvy Consultants Ltd. (‘appellant’) against the order passed by the Adjudicating Authority (‘AA’) under the Prevention of Money Laundering Act, 2002 (‘PMLA’) whereby the Provisional Attachment Order (‘PAO’) of FDR of Rs 65 lakh in the name of Karvy Consultants was confirmed. Balesh Kumar (Member) observed that the amount was nothing but proceeds of crime received from the key operators in the 2005 IPO Scam. Further, Karvy Consultants processed the applications of fictitious applicants for the purpose of transferring the allotted shares from them to the key operators and also received Rs 1 crore from the key operators.
[Karvy Consultants Ltd. v. Enforcement Directorate, FPA/PMLA/581/AHD/2014] Read more HERE
KARNATAKA HIGH COURT | ‘Procedure under S. 174 BNSS not followed’: Criminal proceedings quashed in ‘Matka’ gambling case
In a petition filed under Section 528 of Nagarik Suraksha Sanhita, 2023 (‘BNSS’) praying to quash the criminal proceedings in ‘Matka’ gambling case, V. Srishananda, J.* opined that the Station House Officer (‘SHO’) had not only registered the case but investigated the matter and filed the final report without following the procedure as contemplated under Section 174 of BNSS. Thus, the Court quashed the criminal proceedings in the Matka gambilng case. Read more HERE
PMLA AND MONEY LAUNDERING JURISPRUDENCE
BOMBAY HIGH COURT | IPC offences in the PMLA Schedule must be interpreted as dynamically updated to their corresponding provisions under BNS: Bombay HC.
In the instant bail application, the Court had to consider whether the references made in the Prevention of Money Laundering Act, 2002 (‘PMLA’) to the provisions of the Penal Code, 1860 (IPC) and the Code of Criminal Procedure, 1973 (CrPC), had been rendered ineffective by virtue of their repeal through the Bharatiya Nyaya Sanhita, 2023 (BNS) and the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS). A Single Judge Bench of Amit Borkar, J., held that references to the IPC offences in the PMLA Schedule must be interpreted as dynamically updated to their corresponding provisions under the BNS, considering Section 8(1) of the General Clauses Act, 1897 (the ‘1897 Act’). The Court further affirmed that the repeal and re-enactment of the Penal Code, 1860 (‘IPC’) does not render the PMLA inoperative, and its enforcement remains fully valid and continuous.
[Nagani Akram Mohammad Shafi v. Union of India, 2025 SCC OnLine Bom 2586] Read more HERE
KERALA HIGH COURT | ‘Investigation reveals accused’s active role and link to proceeds of crime’: Kerala HC denies bail in Chinese Loan App Money Laundering Case.
In the Chinese loan App money laundering case, the Single Judge Bench of Bechu Kurian Thomas, J., dismissed the bail application, citing the serious nature of the allegations and the strong prima facie case established against the accused. The Court held that the facts emerging from the investigation clearly indicated the accused’s active involvement in the alleged offence and his significant role in acquiring and managing the proceeds of crime. The Enforcement Directorate had collected material that constituted a prima facie case under Section 3 read with Section 4 of the Prevention of Money Laundering Act, 2002.
[Sayid Muhammed v. Directorate of Enforcement, 2025 SCC OnLine Ker 5361] Read more HERE
MADRAS HIGH COURT | ‘ED is not a Super-Cop’: Madras High Court reiterates presence of predicate offence being essential ingredient for ED to seize jurisdiction
In a case stemming from coal allocation scam of 2018, the Division Bench comprising of M.S. Ramesh and V. Lakshminarayanan*, JJ., opined that if, even after nine years since filing of charge-sheet by CBI, ED is unable to trace the proceeds of crime to the coal allocation scam, then it cannot possess jurisdiction based on the phantoms it sees in the charge-sheet. The Court emphasised on the fact that ED is not a super-cop to investigate everything which comes to its notice. There should be a “criminal activity” which attracts the schedule to PMLA, and on account of such criminal activity, there should have been “proceeds of crime” for ED to commence its jurisdiction.
[R.K.M Powergen Pvt. Ltd. v. Directorate of Enforcement, 2025 SCC OnLine Mad 3272] Read more HERE
SUPREME COURT | Supreme Court grants relief to M3M Group; Permits substitution of attached land in PMLA case
In a Special Leave Petition filed by M3M Group challenging an order passed by the Sikkim High Court, the division bench of Pamidighantam Sri Narasimha and R. Mahadevan, JJ. permitted the substitution of attached land with an alternative property, thereby paving the way for the commencement of a flagship project at the site.
[The Joint Director v. Eastern Institute for Integrated Learning in Management University, 2025 SCC OnLine SC 1395] Read more HERE
PUBLIC SECTOR AND GOVERNMENT CONTRACT FRAUD
BOMBAY HIGH COURT | ‘Authorities stood motionless for 5 years’; Bombay HC imposes Rs 10000 cost each on authorities for failing to act in UIDAI identity fraud case
The present writ petition was filed by the petitioner under Article 226 of the Constitution, after his Aadhaar and PAN details were fraudulently used to open a bank account, obtain GST registration and conduct business transactions and despite repeated complaints, none of the statutory agencies including Unique Identification Authority of India (‘UIDAI’), Income Tax Department, Union Bank, and GST authorities took timely action. The Division Bench of M.S. Sonak and Jitendra Jain*, JJ., while allowing the petition held that the prolonged inaction of the statutory and regulatory authorities amounted to a serious dereliction of their duties, emphasising that they failed to discharge their legal obligations by not taking any action since the last five years of the discovery of fraud committed on them. Further, the Court imposed cost of Rs 10,000 on each of the authorities, which was to be paid to the petitioner for their dereliction of duty.
[Vilas Prabhakar Lad v. Unique Identification Authority of India, 2025 SCC OnLine Bom 2724] Read more HERE
SUPREME COURT | Discharge order based on defence material held impermissible by SC in Rs. 21 Crore MSP fraud case involving Cotton Corporation of India officer
In a batch of civil appeals by the Central Bureau of Investigation against Andhra Pradesh High Court’s decision, the Division Bench of Pankaj Mithal and SVN Bhatti delineated the contours of a magistrate’s discretion under Section 239 of the CrPC, and set aside concurrent findings of discharge by the Special Court and High Court, reiterated that reliance on material produced by the accused at the stage of discharge is impermissible in law. The Court emphasised that the threshold under Section 239 must be assessed solely on the basis of the police report and accompanying documents filed under Section 173 CrPC.
[State v. Eluri Srinivasa Chakravarthi, 2025 SCC OnLine SC 1215] Read more HERE
IDENTITY FRAUD
THE NATIONAL HUMAN RIGHTS COMMISSION | Fake Cardiologist Scam at Damoh Hospital: NHRC uncovers several irregularities; recommends stringent actions
On 07-07-2025, the National Human Rights Commission (‘NHRC’) released findings from its inquiry into a fake cardiologist at Mission Hospital in Damoh, Madhya Pradesh. The Commission had registered the case on 28-04-2025. Upon finding numerous irregularities in the case and issued strong recommendations to both the Government of Madhya Pradesh and the Centre, seeking action to be taken within four weeks, the NHRC recommended that the Chief Secretary, Government of Madhya Pradesh, pay Rs. 10 Lakh each as compensation to the next of kin of the seven patients who died after being treated by the fake cardiologist. It also called for the cancellation of Mission Hospital’s license until the matter is resolved and urged the State Government to inspect all functional Cath Labs in Madhya Pradesh. The NHRC further directed the State Government to issue necessary directions to verify whether all the doctors are qualified to work in the Cath labs or not. Read more HERE
REAL ESTATE AND LAND FRAUD
PUNJAB AND HARYANA HIGH COURT | ‘Serious, structured, and systemic fraud’; Punjab &Haryana HC refuses anticipatory bail to accused in 8-acre land grab case involving DSP, Tehsildar
In a batch of anticipatory bail applications filed in connection with an FIR registered by the Central Bureau of Investigation (‘CBI’) against the accused persons under Sections 120-B, 452, 323, 506, 427, 148, 149,193, 408, 420, 467, 468, 471 of the Penal Code, 1860 (‘IPC’) for allegedly attempting to grab land belonging to a public trust, the Single Judge Bench of Manjari Nehru Kaul, J., rejected the applications holding that the there was no ground to extend the extraordinary concession of anticipatory bail to the accused persons given the seriousness of allegations, possibility of further interference with the trial, and imperative need for custodial interrogation.
[Rajesh Kumar Gaba v. Central Bureau of Investigation, 2025 SCC OnLine P&H 3804] Read more HERE
SECURITIES AND CORPORATE GOVERNANCE VIOLATION
DELHI HIGH COURT | ‘Corporate Veil may be pierced when corporate structure is being used to perpetrate fraud’; Delhi HC holds directors liable for cheque dishonour.
In a revision petition filed against the order passed by the District Commercial Court, Saket, wherein the District Court had pierced the corporate veil to hold the petitioners personally liable for dishonour of cheque, the Single Judge Bench of Amit Mahajan, J*, opined that where the corporate structure is being used for illegal activities, the Court is empowered to disregard the separate legal entity accorded to the company to hold the directors personally liable.
[Ajay Gupta v. Amit Sales Corporation Pvt. Ltd., 2025 SCC OnLine Del 4703] Read more HERE
SECURITIES AND EXCHANGE BOARD OF INDIA | SEBI restrains JS Group from accessing securities market; prohibits buying/selling/dealing in Securities.
An interim ex-parte order was passed by the Securities and Exchange Board of India (‘SEBI’) against the Jane Street Group (‘JS Group’) comprising both Indian and its associated entities, alleging unauthorized use of their proprietary trading strategies in Indian options markets to manipulate the settlement prices of indices like BANKNIFTY and NIFTY. Ananth Narayan G (Whole Time Member), held that the Entities had violated Section 12-A(a), 12-A(b), and 12-A(c) of the SEBI Act, 1992 (‘SEBI Act’) and Regulations 3(a), 3(b), 3(c), 3(d), 4(1), 4(2)(a), and 4(2)(e) of the Prohibition of Fraudulent and Unfair Trade Practices (‘PFUTP’) Regulations, 2003 by using unfair trading practices. SEBI passed an order to impound Rs 4,843.57 crore of illegal gains and restrained the Entities from accessing the securities market and they were further prohibited from buying, selling, or otherwise dealing in securities, directly or indirectly.
[In the matter of Index manipulation by Jane Street Group, WTM/AN/MRD/MRD-SEC-3/31516/2025-26] Read more HERE
SECURITIES AND EXCHANGE BOARD OF INDIA | SEBI penalises Cressanda promoters for disclosure delay, imposes Rs 12 lakh fine
The Securities and Exchange Board of India (‘SEBI’) initiated adjudicating proceedings against Smart Infraproperties (P) Ltd. (‘Smart Infraproperties’) and Yuvika Tradewing LLP (‘Yuvika Tradewing’), for delayed disclosure under Regulations 29(1) and 29(2) read with Regulation 29(3) of Substantial Acquisition of Shares and Takeovers Regulations, 2011 (‘SAST Regulations’). Jai Sebastian (Adjudicating Officer) found both noticees guilty of non-compliance and failure to make timely disclosures regarding their share transactions in Cressanda Railway Solutions Ltd. (‘Cressanda’). Consequently, a penalty of Rs 10,00,000 was imposed on Smart Infraproperties and Rs 2,00,000 on Yuvika Tradewing.
[In the matter of Cressanda Solutions Ltd., Adjudication Order No. Order/JS/YK/2025-26/31531-31532] Read more HERE
CORRUPTION AND BRIBERY
CHHATTISGARH HIGH COURT | “Granting him bail would embolden corrupt practices”: Chhattisgarh HC denies bail to accused in Rs 411 Crore Hamar-Lab scam.
In a bail application filed by an accused in the Hamar-Lab scam worth Rs 411 Crores, the Single Judge Bench of Ramesh Sinha, CJ., rejected the application, holding that the evidence prima facie disclosed that the investigation established the accused as the mastermind of the scam and the acts committed by him were not only grave economic offences but also crimes against the welfare of society at large.
[Shashank Chopda v. State of Chhattisgarh, 2025 SCC OnLine Chh 6457] Read more HERE
LEGISLATION UPDATES
Income Tax Department: Verification operation to curb fraudulent ITR filing.
On 14-7-2025, the Income Tax Department initiated a verification operation across multiple locations in the country, targeting individuals and entities facilitating fraudulent claims of deductions and exemptions in Income Tax Returns (‘ITR’) to curb misuse of tax benefits under Income-tax Act, 1961. Read more HERE
RBI Advises Banks to Integrate DoT’s Financial Fraud Risk Indicator: A step to control cyber- enabled financial frauds
On 30-06-2025, the Reserve Bank of India’s (‘RBI’) issued advisory directing all Scheduled Commercial Banks, Small Finance Banks, Payments Banks, and Co-operative Banks to integrate the Financial Fraud Risk Indicator developed by Department of Telecommunications (‘DoT’) into their systems to fight against cyber-enabled financial frauds. DoT welcomed this watershed moment in the fight against cyber-enabled financial frauds that underscores the strategic importance of automating data exchange between banks and DoT’s DIP through API-based integration, enabling real-time responsiveness and continuous feedback to further refine the fraud risk models. Read more HERE
