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Supreme Court of India 2021-02-03 allowed

OPTO Circuit India Ltd vs Axis Bank & Ors

Bench: 3 — S.A. Bobde, A.S. Bopanna, V. Ramasubramanian

In Brief

OPTO Circuit India Ltd challenged the freezing of its bank accounts by the Enforcement Directorate under the Prevention of Money Laundering Act, 2002 (PMLA), initiated following a CBI investigation into alleged cheating and fund diversion. The High Court upheld the authority's power to initiate PMLA proceedings but the Supreme Court found the freezing invalid due to non-compliance with mandatory procedural requirements under Section 17 of PMLA. The Court held that statutory powers must be exercised strictly according to prescribed procedures, and cannot be validated by post-hoc explanations. Accordingly, the Court directed defreezing of the accounts and payment of cheques for statutory dues (ITDS, PF, ESI, etc.), while preserving the authority's right to initiate action afresh with proper procedural compliance.

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Prevention of Money Laundering Search and Seizure Administrative Law – Procedural Compliance Bank Accounts – Freezing/Defreezing Statutory Authority – Exercise of Power Due Process Criminal Procedure

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