Transfer of PMLA Proceedings Based on Jurisdictional Convenience and Clubbing of Scheduled Offences

Case Snapshot

• Case Name: Amit Katyal v. Union of India & Anr.

• Citation: 2026 INSC 702

• Bench: Chief Justice Surya Kant and Justice Joymalya Bagchi

• Date of Judgment: July 14, 2026

• Area of Law: Prevention of Money Laundering Act, 2002; Criminal Procedure; Transfer of Cases; Jurisdiction

Judgment in Brief

The Supreme Court directed the transfer of PMLA proceedings pending against the petitioner from the Special Court, PMLA, Gurugram, Haryana, to the Special Court, PMLA, Saket Court Complex, Delhi. While declining to quash the prosecution complaint, the Court held that part of the offence under Section 4 of the PMLA had occurred in Delhi by way of concealment of proceeds of crime, giving simultaneous jurisdiction to both courts. Additionally, the scheduled offence (FIR No. 439/2024) had already been transferred to Delhi and clubbed with another FIR. To give effect to the statutory mandate under Section 44(1) of the PMLA, which requires both the PMLA offence and the scheduled offence to be tried by the same Special Court, the transfer was ordered. The Court distinguished the earlier decision in KA Rauf Sherif v. Directorate of Enforcement on facts.

Relevant Facts

• The petitioner was a promoter of M/s Krrish Realtech Pvt. Ltd., which was developing a real estate project called 'Krrish World' in Gurugram.

• Allegations of cheating homebuyers led to multiple criminal cases against the company and its directors.

• ECIR/GNZO/04/2023 dated March 3, 2023, was registered under the PMLA based on six scheduled offences.

• During investigation, further evidence surfaced, leading to the registration of a new scheduled offence (FIR No. 439/2024 dated December 21, 2024) by the Economic Offences Wing, Gurugram Police, under Sections 120B, 406, 409, 411

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