Case Synopsis

State of West Bengal vs Anil Kumar Dey (2025 INSC 1413)

The Supreme Court holds that police can freeze bank accounts under Section 102 CrPC during corruption investigations; this power co-exists with the special attachment procedure under Section 18A of the Prevention of Corruption Act.

Investigative Seizure and Judicial Attachment: Supreme Court Clarifies the Coexistence of Section 102 CrPC and Section 18A PC Act Powers.

1. Heading of the Judgment

Case Name: State of West Bengal vs Anil Kumar Dey
Citation: 2025 INSC 1413
Court: Supreme Court of India
Judges: Hon'ble Mr. Justice Sanjay Karol, Hon'ble Mr. Justice Prashant Kumar Mishra
Date of Judgment: December 10, 2025

2. Related Laws and Sections

• Prevention of Corruption Act, 1988 (PC Act):
  Section 13: Criminal misconduct by a public servant (disproportionate assets).
  Section 18A: Application of the Criminal Law Amendment Ordinance, 1944 to attachment proceedings under the PC Act.

• Code of Criminal Procedure, 1973 (CrPC):
  Section 102: Power of police officer to seize certain property.

• Criminal Law Amendment Ordinance, 1944:
  Sections 3 & 4: Procedure for application and ad-interim attachment of property.

• Indian Penal Code, 1860:
  Secti

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