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JSW Steel Limited vs. Deputy Director, Directorate of Enforcement

Not available · 2025 INSC 1194Decided 7 Oct 2025
Not available
Justice Dipankar Datta · Justice Augustine George Masih

Background

JSW Steel Limited and one of its compliance officers challenged proceedings under the PMLA arising from ECIR/09/BZ/2012, including a Special Court order taking cognizance of offences and issuing summons against them. The proceedings stemmed from JSW's supply contract with Obulapuram Mining Company for iron ore, with part of the allegations relating to how certain payments/withdrawals connected to the contract were made. The Karnataka High Court had dismissed their writ petitions challenging the investigation and the cognizance order, prompting this appeal to the Supreme Court.

Decision Breakdown

The Supreme Court declined to quash the cognizance order or interdict the ongoing PMLA proceedings at this stage, holding that interference now would prejudge issues, such as whether the attached property constitutes "proceeds of crime" under Section 2(1)(u) of the PMLA, that fall squarely within the domain of the Appellate Tribunal. The Court found the allegations, at this stage, confined to recovery of a quantified amount (about Rs. 33.80 crore) and did not extend to broader criminal liability, so the apprehension of arbitrary prosecution was misplaced. The appellants were left free to pursue their statutory appeals before the Appellate Tribunal, and the criminal appeals were disposed of without any order as to costs.

Lesson Learnt

Courts are reluctant to short-circuit PMLA proceedings at an early stage by quashing cognizance orders when statutory appellate remedies (like the Appellate Tribunal) exist to examine factual questions such as whether property qualifies as "proceeds of crime."

Official source (sci.gov.in)View Judgment (PDF)

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