Recently the Enforcement Directorate, India's law enforcement and economic intelligence agency in charge of implementing economic laws and countering economic crime, attached over 1.77 crore to The Washington Post Columnist Rana Ayyub in connection with a money laundering probe, due to alleged irregularities in charitable contributions raised from public fundraisers.

The ED served her with a summons under the Prevention of Money Laundering Act, 2002 in last December. She discovered during her interrogation in Delhi that the PMLA probe was founded on a complaint lodged in Ghaziabad, Uttar Pradesh, in August 2021.

PMLA 2002, the Act enforced in this incident, came into force on July 1, 2005.

Background and Capabilities

During the 90’s, a certain form of Malpractice began and it picked up pace notoriously. Popularly known as Hawala Transactions, it involved trading using illegal means and after receiving the Payday, and disguise it as Legal “White” Money.

Money laundering is the unlawful process of making substantial amounts of money obtained from criminal enterprises, such as narcotics trafficking or financing of terrorism, and later make it appear to have arisen from a legitimate source. The spoils of illicit activities are deemed "dirty," thus the procedure "launders" them to make them appear pure and "legally white".

Another important reason for the existence of this Act is that; even though a lot of legislations penalizing economic offences were already in-effect in the 90’s but none of them addressed the problem of Money Laundering at its core.

To combat and arrest this malpractice, this act was brought up and put into action in 2005. Its primary objectives were to stop money-laundering activities and to confiscate property of the offenders and arrest them.

The act had a slew of provisions and far-reaching powers to reach its objectives.

It prescribed severe punishment for money-laundering activities, which included imprisonment of at least three years, to a maximum of seven years.

However, the Act also provided for a maximum incarceration for a decade, if the matter included infractions warranting NDPS Act. It had assorted powers of attachment of tainted property, which allowed the Authorities to seize the property-in-hand for 180 Days and in cases, where two or more parties are involved in inter-connected transactions, it was presumed that the remaining transactions form a part of such inter-connected transactions.

This power of Presumption of Connections was given a legal sanction through this Act. Moreover, the burden of proof lies not on the prosecution but on the Accused as he/she has to prove that the assets-at-hand are, in fact, lawfully obtained.

For effective prosecution in a timely fashion, the Appellate Tribunal and Special Courts were also established.

As per Section 43 of the act, the Central Government, in consultation with the Chief Justice of the High Court, shall, by notification, appoint one or more Courts of Session as Special Court or Special Courts for such area or areas, or for such case or class or group of cases as may be specified in the notification, for the trial of offence punishable under Section 4.

Legal Flukes and Lawsuits

The major setback for this legislation was the fact that it was constitutionally challenged several times at Indian Judiciary. Its constitutionality was challenged a lot as it was alleged that the Section 45(1) and its two prior conditions, overlooked the principles of Natural Justice and were grossly arbitrary in nature.

Section 45 of the PMLA departs from the rule of presumption of innocence in that it specifies two additional pre-conditions that must be fulfilled before an accused can be granted bail.

The two conditions for release of an accused on bail was held to be unconstitutional as it violated Article 14 and 21 of the Constitution in a landmark judgment of Supreme Court in Nikesh Tarachand Shah v. Union of India.

Apart from Section 45, the validity of Sections 17 and 18 (search and seizure), 5 (attachment of property involved in money laundering), 8 (adjudication) and 45 (bail) have been a matter of long-standing litigation.

One of the powers mentioned above (Burden of Proof) was also deemed to be contrary to what Law says and the basic legal principle of Proof also withered away. As Senior Advocate Dr. Abhishek Manu Singhvi attacked this provision contending “the entire burden of disproving the case as set out in the complaint would rest with the accused person, after the framing of charges. This amounts to a complete inversion of the burden of proof”, during a hearing on a petition involving the Supreme Court's interpretation of provisions of this Act.

The landmark case struck down its provisions, and later in 2018, this Act was amended and the most crucial change is the deletion of provisions in sub-sections (1) of Section 17 (Search and Seizure) and Section 18 (Search of Persons). However, it was still deemed as New Bottle, Old Wine.

Conclusion

The intent of THE PREVENTION OF MONEY LAUNDERING ACT was to counter the threat of money laundering resulting from the “laundering” of ill-gotten riches through illegitimate means. The act's provisions are equally harsh both on the perpetrator and the person in whose name is layered.

However, a number of legal disputes to the constitutional integrity of the Prevention of Money Laundering Act (PMLA) of 2002 have already found their way to the courts. There have been multiple flaws and discrepancies in the Act's provisions since its origin, and as a consequence, it has always been in the limelight. Without a doubt, amendments were made to close loopholes that appeared, but they missed to accomplish the objective for which they were made and instead prompted a variety of problems.


About the Author: This post is prepared by Harsh Dabas, Law student at University School of Law & Legal Studies, Guru Gobind Singh Indraprastha University. He can be reached at harshdabasvbps@gmail.com 

 

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