PMLA Clarity:Deep Dive into the Supreme Court’s Decision in Vijay Madanlal Choudhary Case

 

“PMLA Clarity: Deep Dive into the Supreme Court’s Decision in Vijay Madanlal Choudhary Case”

CASE NAME: Vijay Madanlal Choudhary & Ors. Vs Union of India & Ors.

COURT: Supreme Court of India

DATE OF DECISION: 27th July 2022

CORAM: Justices A.M Khanwilkar, Dinesh Maheswari, and C.T. Ravikumar

INTRODUCTION:

The Vijay Madanlal Choudhary & Ors. Vs Union of India & Ors. case is rooted in the societal issue of money laundering, a criminal activity that poses a threat to the integrity of financial systems and can destabilize economies.

The Prevention of Money Laundering Act, 2002 (PMLA) was enacted to combat money laundering in India. However, certain provisions of the PMLA were challenged as being arbitrary, disproportionate, and infringing upon the constitutional rights of the accused. This led to the case of Vijay Madanlal Choudhary & Ors. Vs Union of India & Ors.

 

FACTS:

The Vijay Madanlal Choudhary & Ors. Vs Union of India & Ors. case emerged from a series of legal challenges to the Prevention of Money Laundering Act, 2002 (PMLA) over a period of fifteen years. These challenges were presented in various forms, including special leave petitions, appeals, and writ petitions.

Several parts of the PMLA were contested by the petitioners, including Vijay Madanlal Choudhary, on grounds of constitutionality. These challenges often stemmed from orders passed by High Courts or subordinate courts that denied applications for discharge, bail, quashing, among others.

The Supreme Court, while dealing with this batch of cases, strategically decided not to delve into the specific facts of each individual case. Instead, the Court chose to focus solely on the legal issues raised in relation to the PMLA provisions. This approach allowed the Court to streamline its examination process and concentrate on the most critical legal issues.

In the specific case of Vijay Madanlal Choudhary, the petitioner filed several Writ Petitions seeking to quash the proceedings and investigation initiated under the PMLA. Additionally, in W.P No. 5625/2015, the petitioner prayed for a writ of Habeas Corpus.

JUDGEMENT OF THE CASE AND ANALYSIS:

The court ruled that the Enforcement Directorate is not required to provide the Enforcement Case Information Report (ECIR) to the accused. The court reasoned that the ECIR is not equivalent to an FIR, and therefore, it does not need to be mandatorily supplied to the accused as per the Code of Criminal Procedure, 1973.

The court further clarified that at the time of arrest, the Enforcement Directorate is only required to inform the accused about the grounds of the arrest. As long as the accused is informed about the grounds of his arrest, it is considered sufficient compliance with Article 22 (1) of the Constitution.

The court also stated that once the complaint is filed before the statutory period provided in the 1973 Code, after arrest, the accused would receive all relevant materials forming part of the complaint filed by the Authority under Section 44 (1) (b) of the 2002 Act before the Special Court.

The court opined that non-supply of ECIR in a given case cannot be faulted. The ECIR may contain details of the material in possession of the Authority and recording satisfaction of reason to believe that the person is guilty of money-laundering offence, if revealed before the inquiry/investigation required to proceed against the property being proceeds of crime including to the person involved in the process or activity connected therewith, may have deleterious impact on the final outcome of the inquiry/investigation.

This judgment is crucial as it strengthens the powers of the Enforcement Directorate under the PMLA, which is an important instrument in the battle against money laundering. By validating the constitutionality of these provisions, the court has ensured that the Enforcement Directorate can continue to carry out its duties effectively.

In my analysis, this judgment is significant as it reinforces the powers of the Enforcement Directorate under the PMLA, which is a crucial tool in the fight against money laundering. By upholding the constitutionality of these provisions, the court has ensured that the Enforcement Directorate can continue to perform its role effectively.

However, the judgment also highlights the need for a balance between law enforcement and the protection of individual rights. While the PMLA is a necessary tool in the fight against money laundering, it’s also important to ensure that its provisions are not misused or applied in a manner that infringes upon the rights of individuals.

Overall, the judgment represents a careful balancing act between the need for effective law enforcement and the protection of individual rights, reflecting the complexities involved in the fight against money laundering.

 

WRITTEN BY: AKSHAYA ZAVAR

 

The Supreme Court of India

 

 

Unfold Law – Law Firm in Bangalore, Lawyers in Bangalore

 

This Post Has 75 Comments

  1. Tanu aggarwal

    🔍 Explore the nuances of the Supreme Court’s decision in the Vijay Madanlal Choudhary case, shedding light on key legal aspects of the Prevention of Money Laundering Act, 2002 (PMLA). Learn about the court’s rulings regarding the Enforcement Case Information Report (ECIR) and the rights of the accused. #SupremeCourt #PMLA 📜⚖️

  2. Sakshi Rathour

    What an insightful article this is! Your words paint such a vivid picture. I especially like how you highlight a specific aspect, such as your storytelling style or a particular insight. Thanks for sharing your perspective. I’m already looking forward to your next post.Paharganj Escorts Services

  3. Heena

    If you are looking for an attractive and seductive female companion in Karol Bagh, then you have come to the right place! We provide Superclass Hot and Sexy Indian Call Girls in Karol Bagh, A to Z Body and Mind Satisfaction by Top Class Delhi Escorts.
    Escort Service In Karol Bagh

  4. Heena

    If you are looking for an attractive and seductive female companion in Karol Bagh, then you have come to the right place! We provide Superclass Hot and Sexy Indian Call Girls in Karol Bagh, A to Z Body and Mind Satisfaction by Top Class Delhi Escorts. Get 24×7 Escort Services Near me, Here the Collection of Premium Independent Call Girls in Delhi.
    Karol Bagh Call Girls

  5. Rosina Mcpeck

    I like this site its a master peace ! Glad I detected this on google

  6. Maritza Dotzler

    What is Leanbiome? LeanBiome is a dietary supplement that is formulated with nine critically-researched lean bacteria species

  7. Pinky

    Upon entering our spa, you will be greeted by a serene atmosphere that immediately puts you at ease.Russian spa in aerocity Russian spa in Delhi Aerocity.9319033293 Nestled in the heart of Mahipalpur, Aerocity, Delhi,Our therapists use a combination of techniques to ensure that every knot and tension point is addressed,full-body-massage-delhi.html leaving you feeling lighter and more relaxed. The deep tissue massage not only alleviates physical discomfort but also promotes mental clarity and emotional well-being.

  8. Darmowe konto na Binance

    Can you be more specific about the content of your article? After reading it, I still have some doubts. Hope you can help me.

  9. auto approve list

    Normally I do not read article on blogs, but I wish to say that this write-up very forced me to take a look at and do it!

    Your writing taste has been amazed me. Thanks, quite
    nice article.!

  10. eco product

    Hey there! Do you know if they make any plugins to help with
    Search Engine Optimization? I’m trying to get my website to rank
    for some targeted keywords but I’m not seeing very good gains.
    If you know of any please share. Thank you! I saw similar article
    here: Warm blankets

  11. sugar defender official website As someone
    that’s always been cautious about my blood
    glucose, discovering Sugar Protector has actually been a relief.

    I really feel a lot a lot more in control, and my current check-ups
    have revealed positive improvements. Recognizing I have a trusted supplement to support
    my routine gives me comfort. I’m so grateful for Sugar Defender’s impact on my health!

  12. Vavada PL

    You need to be a part of a contest for one of the greatest sites on the web. I most certainly will highly recommend this web site!

  13. pandora jewelry

    Right here is the right web site for anyone who really wants to find out about this topic. You understand so much its almost tough to argue with you (not that I personally would want to…HaHa). You certainly put a new spin on a subject that has been discussed for decades. Wonderful stuff, just wonderful.

  14. Hi there, I believe your blog may be having internet browser compatibility problems. Whenever I take a look at your site in Safari, it looks fine but when opening in I.E., it’s got some overlapping issues. I simply wanted to provide you with a quick heads up! Besides that, wonderful website!

  15. 라카지노 사이트

    I’d like to thank you for the efforts you have put in penning this website. I really hope to check out the same high-grade content from you in the future as well. In truth, your creative writing abilities has inspired me to get my own website now 😉

  16. what's trending today

    Everything is very open with a very clear description of the challenges. It was truly informative. Your website is very useful. Thanks for sharing.

  17. erotikfoto

    Updegrave, Walter. “Should you utilize an IRA to repay debt?” CNN Money.

  18. Nice post. I learn something new and challenging on blogs I stumbleupon everyday. It’s always interesting to read through content from other writers and use a little something from other sites.

  19. Forgers buy actual American Revolutionary Warfare-period documents and surreptitiously pen a well-known patriot’s identify between other actual signatures in a manuscript in hope of deceiving an unsuspecting purchaser.

  20. otc 株価

    When it comes to planning and decoration working in group is at all times wanted and the most effective possibility.

  21. 投資 計算

    Given this data, one might marvel why folks aren’t paying extra consideration to and investing in the event of wave energy.

  22. Enhance your industrial operations with BWER weighbridges, designed for exceptional accuracy and durability to support Iraq’s growing infrastructure and logistics sectors.

  23. nkジャパン

    The MFA pays as much as $10,000 for one declare per lively-responsibility order in a 12-month period.

  24. Good day! Do you know if they make any plugins to protect against hackers? I’m kinda paranoid about losing everything I’ve worked hard on. Any recommendations?

  25. snaptik

    I’m amazed, I have to admit. Seldom do I come across a blog that’s both educative and entertaining, and without a doubt, you’ve hit the nail on the head. The issue is something that too few men and women are speaking intelligently about. I am very happy I came across this during my hunt for something relating to this.

  26. rent scaffolding near me

    hi!,I like your writing so much! share we communicate more about your post on AOL? I need an expert on this area to solve my problem. Maybe that’s you! Looking forward to see you.

  27. scaffolding for sale

    The paragraph is worth to examine. The clarity as well as structure that shines from this internet site post. Now-a-days blogs are used in each in addition to every field. The information that we recieve from them are unevitable. The attribute required is the power of creativity within itself through learning, thinking, creating along with rigorous learning. Therefore the internet site post is immensely helpful for the readers. Thank you a lot for writing form a magnificent editorial. I will wait for your next editorial with grand egarness.

  28. tubidy music

    This is the right site for anyone who wishes to find out about this topic. You know a whole lot its almost tough to argue with you (not that I really will need to…HaHa). You certainly put a fresh spin on a topic that has been written about for many years. Excellent stuff, just excellent.

  29. adjustable scaffolding

    Hey dude” what kind of wordpress theme are you using? i want it to use on my blog too “  

  30. used scaffolding

    certainly like your web-site however you have to test the spelling on quite a few of your posts. A number of them are rife with spelling issues and I to find it very bothersome to inform the reality on the other hand I will certainly come again again.

  31. alloy scaffold tower

    I would read more on this topic if the info provided were as interesting as what you have written in this article. Don’t stop caring about the content you write.

  32. aluminium tower

    I’d have got to consult with you here. Which isn’t some thing Which i do! I love reading an article that will get people to feel. Also, appreciate your allowing me to comment!

  33. metal tech scaffold

    You lost me, friend. I mean, I assume I get what youre indicating. I have an understanding of what you are saying, but you just appear to have forgotten that you will find some other people inside the world who view this issue for what it really is and may possibly not agree with you. You may be turning away a decent amount of people who may have been fans of your website.

  34. instagram reels downloader

    Aw, this was an extremely good post. Finding the time and actual effort to produce a great article… but what can I say… I put things off a lot and never manage to get anything done.

  35. alloy tower

    Well done! I thank you your contribution to this matter. It has been insightful. my blog: how to get rid of love handles

  36. painters scaffold

    Hey there! Someone in my Facebook group shared this website with us so I came to check it out. I’m definitely enjoying the information. I’m book-marking and will be tweeting this to my followers! Superb blog and wonderful design.

  37. metal tech scaffold

    Naturally I like your web-site, but you have to take a look at the spelling on quite a few of your posts. A number of them are rife with spelling issues and I find it very bothersome to tell you. On the other hand I’ll surely come back again!

  38. painters scaffold

    You’re the best, Your post is an excellent example of why I keep coming back to read your excellent quality content….

  39. You’re so awesome! I do not believe I’ve read through a single thing like that before. So great to discover somebody with a few original thoughts on this issue. Seriously.. thanks for starting this up. This web site is something that’s needed on the internet, someone with some originality.

  40. scaffolding

    My brother suggested I might like this website. He was totally right. This post actually made my day. You can not imagine just how much time I had spent for this info! Thanks!

  41. alloy scaffold tower

    You made some decent points there. I looked on the internet for any issue and located most individuals should go in addition to with the website.

  42. mobile scaffold

    Hello my loved one! I wish to say that this article is awesome, nice written and come with almost all significant infos. I¡¦d like to look extra posts like this .

  43. narrow scaffold tower

    You should participate in a contest for probably the greatest blogs on the web. I will recommend this website!

  44. scaffold jacks

    Oh my goodness! an incredible article dude. Thank you Nonetheless I am experiencing problem with ur rss . Don’t know why Unable to subscribe to it. Is there anyone getting an identical rss downside? Anyone who is aware of kindly respond. Thnkx

  45. mobile scaffold tower

    Hello. Neat post. There is an issue with your site in firefox, and you may want to test this… The browser is the market chief and a big part of other people will miss your wonderful writing because of this problem.

  46. scaffolding

    I appreciate bothering to debate now this, I believe truly about this plus enjoy knowing read more about this method subject matter. In case promising, as soon as you get to skill, is it possible you opinions adding all your web site by working with in depth content? This is used for me personally.

  47. aluminium tower

    This web site is often a walk-through for all of the knowledge you wanted concerning this and didn’t know who must. Glimpse here, and you’ll absolutely discover it.

  48. Granted, you do not all the time have the opportunity to go into as much detail in your presentation as you would like, nevertheless it opens the door for future communications — a door that typically may be very difficult to get your foot into.

  49. scaffold stairs

    Hi! I ran across your site accidentally today, but am really pleased that people did! Its not only entertaining, but additionally straightforward to make use of compared with lots that Ive viewed!

  50. 5m scaffold tower

    It is best to participate in a contest for the most effective blogs on the web. I’ll advocate this website!

  51. home scaffolding

    The internet insurance estimates allow individuals to take over questionnaires anytime. The principal thing they’ve to become is which you can follow the approach to obtain a particular estimate the auto insurance cover.

  52. telescopic scaffold tower

    I really appreciate this post. I’ve been looking all over for this! Thank God I found it on Bing. You’ve made my day! Thx again…

  53. reference

    This site truly has all of the info I needed about this subject and didn’t know who to ask.

  54. lewis scaffold tower

    Wow that was odd. I just wrote an incredibly long comment but after I clicked submit my comment didn’t show up. Duch Œwiêty Grrrr… well I’m not writing all that over again. Anyways, just wanted to say fantastic blog!

  55. Hello there I am so glad I found your blog page, I really found you by mistake, while I was looking on Bing for something else, Anyways I am here now and would just like to say thanks a lot for a marvelous post and a all round entertaining blog (I also love the theme/design), I donít have time to browse it all at the moment but I have book-marked it and also included your RSS feeds, so when I have time I will be back to read more, Please do keep up the awesome job.

  56. aluminium scaffold tower

    One can undertake all sorts of advised excursions with assorted limousine functions. Various offer great courses and many can take clients for just about any ride your bike over the investment banking area, or even for a vacation to new york. ???????

  57. indoor scaffolding

    I real glad to find this web site on bing, just what I was searching for : D likewise saved to bookmarks .

  58. scaffold platform

    Many thanks for posting this, It?s just what I was researching for on bing. I?d so much comparatively hear opinions from a person, barely than an organization internet page, that?s why I like blogs so significantly. Many thanks!

  59. werner scaffolding

    Youre so cool! I dont suppose Ive read anything like that just before. So nice to seek out somebody by incorporating original applying for grants this subject. realy we appreciate you starting this up. this fabulous website can be something that is required on the net, someone after some originality. helpful purpose of bringing interesting things to the web!

  60. zone-controlled heating

    Just before entering into verifying a money back guarantee reputation, I am required to mention a couple reasons for levy refunds.

  61. gas safe register

    housewarming Harmi bring about Frinel paraclete dubin sjankata poncela seeds

  62. boiler installation

    Nice post. I discover something harder on distinct blogs everyday. Most commonly it is stimulating to learn content using their company writers and practice a little from their site. I’d choose to apply certain using the content on my own weblog regardless of whether you do not mind. Natually I’ll supply you with a link on your web blog. Thank you sharing.

  63. gas pipe relining

    I discovered your web site very informative maintain up the superior work

  64. The Schuylkill River above Fairmount Dam has been a serious rowing venue since the founding of the Schuylkill Navy in 1858.

  65. For those who examine the “No” box, you cannot take the energy environment friendly dwelling enchancment credit to your residential energy property costs.

  66. Halloween Horror Nights V featured a 12-night time run and three haunted houses, one in all which was a twin-path house.

Leave a Reply