Interim Order 15

Order Details: COPY OF ORDER
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Order dated 10.02.2026 in Ct. Case No. 32/2024; CNR No. DLCT11-001235-2024; Directorate of Enforcement (DoE) Vs. Venugopal
Nandlal Dhoot @ V. N. Dhoot & Ors.
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In the Court of Dig Vinay Singh, Special Judge, CBI-09, (PC Act)
MPs/MLAs Cases, Rouse Avenue Courts, New Delhi.
In re:
Ct. Case No. 32/2024
CNR No. DLCT11-001235-2024
U/s 45 r/w 44 of PMLA, 2002 for
offence U/s 3/4 of PMLA
Directorate of Enforcement (DoE)
Vs.
1. Venugopal Nandlal Dhoot @ V. N. Dhoot
2. Pradip Kumar Nandlal Dhoot @ P. N. Dhoot
3. Rajkumar Nandlal Dhoot @ R. N. Dhoot (Ex. MP)
4. M/s Videocon Industries Ltd. (VIL)
5. M/s Videocon Oil Ventures Ltd. (VOVL)
6. M/s Videocon Hydrocarbon Holdings Ltd. (VHHL)
7. M/s Venus Corporation Ltd. (VCL)
8. M/s Eagle Corporation Ltd. (ECL)
9. M/s Quadrant Corporation Ltd. (QCL)
10. M/s Paramount Global Ltd. (PGL)
11. M/s TGDC Guangdong Display Devices Co. Ltd. (TGDC)
12. M/s Videocon Realty and Infrastructure Pvt. Ltd. (VRIL)
13. M/s VDC Technologies SPA (VDCT)
10.02.2026
ORDER
1. This order determines whether to take cognizance of offences U/s 3 &
4 of the Prevention of Money Laundering Act, 2002 (PMLA). The
complainant, DoE, filed the present complaint U/s 44 & 45 of PMLA
for the offences u/s 3 & 4 of PMLA against 13 proposed accused
persons/entities. The predicate offence is stated to be still under
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investigation by the CBI under FIR No. RC2172020A0002 dated
23.06.2020. That was registered for offences u/s 120B/420 of the IPC
and Section 13(2) r/w 13(1)(d) of the PC Act 1988.
2. Since the complaint was instituted post the coming into force of
Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), in terms of the
proviso to Sub-Sec 1 of Sec. 223 of the BNSS, a notice was issued to
all 13 individuals & entities. Out of 13 proposed accused, only A1 to
A4 were represented and participated in the hearings. For the remaining
proposed A5 to A13, no one appeared despite the service of notice. A1
to A4 contested the proceedings, claiming that cognizance cannot be
taken.
3. Since the point of cognizance is to be determined, and the object of
introducing the first proviso to Sec. 223(1) BNSS is to nip frivolous
litigation in the bud, and the threshold at this stage of the matter is even
lower than the threshold applied while considering charge or
discharging an accused, it has to be borne in mind that at this stage of
the matter the accused can raise only preliminary objections, such as to
the frivolity or legal bars to the complaints, including lack of
jurisdiction, being barred by time, or the complainant being legally
incompetent, or that even if the allegations in the complaint are taken
to be 100% true, no offence is disclosed. At this stage, the veracity of
the allegations cannot be determined, and they must be taken to be true
on their face. The standard applied has to be lower than the disclosure
of a strong suspicion, which is applied at the stage of discharging an
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accused or framing a charge. Thus, if the complaint, taken as a whole,
discloses the commission of an offence, that would suffice for taking
cognizance. At this stage, the Court is only required to find sufficient
grounds for proceeding, not to conduct a mini-trial or to evaluate the
probative value of the evidence. Keeping in mind the principle of law,
the contentions raised by the proposed A1 to A4 are hereby examined.
4. The defence has mainly raised similar pleas. It is contended on behalf
of the proposed accused that the complaint is a gross abuse of process
and legally unsustainable on the following grounds.
4.1. It is argued that the FIR in the predicate offence is void ab initio because
it was registered in violation of Section 17A of the PC Act, 1988, which
mandates prior approval from the competent authority before
investigating public servants (bank officials in the predicate offence)
for their official decisions. It is claimed that this is not a mere procedural
irregularity but a substantial illegality going to the root of jurisdiction.
4.2. It is also argued that the FIR in the predicate offence invokes Sec 13(1)
(d) of the PC Act, which stood repealed in the year 2018, i.e., two years
prior to the registration of the FIR; therefore, the FIR is also void.
4.3. It is further claimed that the CBI, which registered the predicate
offence, failed to refer the case to the Advisory Board for Banking and
Financial Frauds (ABBF), as mandated by the Central Vigilance
Commission (CVC) for large-scale fraud investigations.
4.4. It is argued that the underlying transactions were legitimate business
decisions approved by the Joint Lenders’ Forum (JLF). The lending
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banks have not alleged any such fraud and are adequately secured with
assets valued at approximately 9.9 billion USD (US Dollars) against an
exposure of 2.774 billion USD.
4.5. It is also claimed that the complainant has failed to identify any specific
property or value that constitutes ‘proceeds of crime’ as defined in
Section 2(1)(u) of PMLA, and the general allegations of diversions or
layering without precise transactional tracing are legally inadequate.
4.6. It is also claimed that the DoE has extended its inquiry beyond the scope
of the CBI’s FIR, while looking into pre-2012 dealings and other group
entities not mentioned in the original FIR of the predicate offence,
which is impermissible and an act of overreach i.e. unsanctioned by
law.
4.7. It is also claimed that even if the allegations are taken at face value, they
fail to disclose the commission of any offence, as the necessary
ingredients of cheating, criminal conspiracy or criminal misconduct are
not made out.
4.8. It is also argued that the role of the proposed A2 was purely nominal
due to family relations, with no operational control or involvement in
the financial decision-making. A-2 sought to present a detailed factual
rebuttal, point by point, to each allegation, which is beyond the scope
of the present stage.
4.9. Proposed A3 asserts that his functions were merely ministerial and
administrative, lacking the necessary
mens rea for money laundering.
A-3 also sought to present a defence that there was a complete lack of
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control, knowledge or participation by A-3 in the company, and that he
did not play any role in the functioning or operations of the accused
entities, which again is beyond the scope at the time of taking
cognizance.
4.10. On behalf of A4, it is claimed that, as this company is in the process of
insolvency under the Insolvency & Bankruptcy Code (IBC), 2016.
Once the resolution plan is approved and management changes hands,
the corporate entity must be protected for the revival of the proposed
A4 under Sec. 32A of the IBC.
5. On the other hand, DoE refutes the defence’s objection, urging that
PMLA is an independent offence and a stand-alone crime. It is argued
that once the PMLA investigation begins, the connection to the
predicate FIR is lost, and PMLA proceedings can continue
independently of the predicate case’s status, provided the accused has
not been finally acquitted or discharged. It is argued that the
investigation uncovered a sophisticated scheme in which USD 2.02
billion was diverted from its intended use, i.e., developing overseas oil
& gas assets. Allegedly, this was achieved through a web of shell
companies, fake utilisation certificates, and complex layering to route
funds back into VIL (proposed A4) to pay off other debts. DoE alleges
that a total loss of Rs. 61,773 Crores occurred to the consortium of
Indian Banks, and it has identified proceeds of crime (POC) amounting
to approximately Rs. 1,136 Crores.
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5.1. DoE has presented a factual matrix alleging the concealment and
layering of massive credit facilities. The investigation into the Videocon
Group originated from findings shared with the CBI following an
inquiry under the Foreign Exchange Management Act (FEMA) in
February 2019. The CBI registered an FIR on 23.06.2020 against the
proposed A-1 V. N. Dhoot and unknown bank officials for the offence
of criminal conspiracy, cheating and misconduct, punishable u/s 120B,
420 of the IPC and Section 13(1)(d) of the PC Act 1988, as it stood prior
to its amendment w.e.f. 26.07.2018. Subsequently, the DoE registered
an Enforcement Case Information Report (ECIR) on 30.06.2020 under
the PMLA to investigate the layering and siphoning of funds.
5.2. The foundation of the alleged fraud involves 3 primary credit facilities
intended for the development of oil and gas assets in Mozambique,
Brazil & Indonesia. These credit facilities included a USD 510 million
“Jupiter Facility” raised in 2009, a second USD 400 million facility
from Standard Chartered Bank (SCB) that was later enhanced to USD
1.256 billion, and a massive USD 2.77 billion Standby Letter of Credit
(SBLC) facility sanctioned in 2012 by an SBI led consortium of 26
banks. Although these funds were legally bound for Energy Asset
Development, the investigation established that USD 2.02 billion was
diverted for other purposes. Specifically, USD 954.01 million from the
SBLC; USD 397.85 million from the Jupiter Facility; and USD 677.31
million from the SCB facility were siphoned away from their mandated
business use.
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5.3. The modus operandi involved a multi-stage process of diversion and
layering. Loan proceeds were remitted to overseas subsidiaries such as
M/s VEBL and M/s VMRL, which then transferred the funds through a
complex web of shell entities, including M/s Eagle (A-8), M/s Venus
(A-7), and M/s Quadrant (A-9), located in jurisdictions such as the
Cayman Islands and Hong Kong. To integrate these illicit funds back
into the Indian economy, the money was returned to the flagship
company, VIL (A-4), disguised as export advances, equity, or loan
repayments. This circular flow of money created a web that allowed
billions to be moved without appearing as suspicious transactions in the
financial statements. To conceal these related-party transactions, V. N.
Dhoot (A-1) strategically reduced the group’s shareholding in these
overseas entities to below 20%, thereby bypassing statutory disclosure
requirements for auditors and lenders. Also, V. N. Dhoot (A-1) allegedly
coerced auditors into signing bogus utilisation certificates to deceive
banks into believing the funds were being used correctly. The
complainant also alleges and highlights significant connivance and
negligence by the bank officials, alleging that the officials failed to
create a first charge on the Mozambique asset, allowing the Videocon
Group to use the same asset as security for undisclosed loans from SCB
even after Indian lenders had paid USD 530 million to SCB in 2013.
5.4. When the Mozambique asset was sold in 2014 for USD 2.519 billion to
a joint venture of ONGC and Oil India, the proceeds were diverted to
settle non-SBLC liabilities, including a USD 118 million dispute with
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Huawei. Approximately USD 1814 million of the sale proceeds were
re-routed back to India through circular transactions to cover up the
previous diversions of loan funds.
5.5. Specific Proceeds of Crime were identified in the personal acquisition
of 10 acres of land in village Manghar for INR 15.36 crore. These funds
were sourced from diverted company loans, but the land was registered
in the personal name of V. N. Dhoot (A-1) and later gifted to his son to
further hide the trail.
5.6. Additionally, INR 7.82 crore was withdrawn in cash from group
accounts for personal enrichment between 2013 and 2017.
5.7. The proceeds parked in M/s TGDC was projected as untainted export
realisations, leading to the concealment also.
5.8. It is alleged that the cumulative effect of these actions led to the
Videocon Group’s accounts becoming non-performing assets (NPA),
resulting in a staggering total loss of INR 61,773.02 crores to the
consortium of Indian banks.
5.9. Currently, VIL (A-4) and its subsidiaries are under the corporate
insolvency resolution process (CIRP), and properties worth INR 17.69
crores have been provisionally attached.
5.10. A-1 V. N. Dhoot is identified as the mastermind and principal decision-
maker, and it is alleged that he orchestrated the diversion of funds,
pressured the auditors to falsify records, and was directly involved in
acquiring and concealing the proceeds of crime for personal use.
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5.11. A-2 P. N. Dhoot allegedly managed the group’s overseas operations
from Dubai. Allegedly he knowingly assisted A-1 by executing fund
transfers and layering proceeds through the web of foreign companies.
5.12. A-3 R. N. Dhoot allegedly assisted the business in India and acted as a
personal guarantor for the credit facilities. He participated in the lender
meetings and decision-making processes that facilitated the movement
of proceeds of crime.
5.13. The corporate entities viz. A-4 VIL, A-5 VOVL, A-6 VHHL, etc. served
as the primary vehicles for obtaining credit facilities and were used to
divert, transfer and layer funds under the control of the Dhoot family.
5.14. The shell entities/conduit entities such as A-7 M/s Venus, A-8 M/s
Eagle, A-9 M/s Quadrant, etc. were overseas companies which were
instrumental as conduits for layering funds and projecting illicit money
as untainted through sham “export advance” transactions.
6. On behalf of A-4, reliance is placed on the cases of
Manish Kumar
Vs. UoI 2021 SCC OnLine SC 30, and the decision of the Hon’ble DHC
in
Bhushan Power and Steel Limited Vs. UoI 2025 SCC OnLine Del
651, wherein the legal position regarding the immunity granted to a
corporate debtor post approval of a resolution plan u/s 32A of IBC 2016
has been settled. However, it is admitted that, to date, there has been no
approval of the resolution plan qua A-4, as in a company appeal, the
Hon’ble NCLAT, vide its order dated 19.07.2021, stayed the order of
approval, and thereafter, vide order dated 05.01.2022, the Hon’ble
NCLAT ruled that the approved resolution plan was not in consonance
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with Section 31 of IBC. Though it is under challenge before the Hon’ble
Supreme Court, there is no final approval of the resolution plan,
admittedly.
7. On behalf of A-1, A-2 and A-3, reliance has been placed on the
following cases:
Vijay Madan Lal Chaudhary and Ors. Vs. UoI (2022)
10 SCC 1; Anil Vasant Rao Deshmukh Vs. State of Maharashtra 2021
SCC OnLine Bom 1192; State of Punjab Vs. Devinder Pal Singh
Bhullar (2011) 14 SCC 770; State of UP Vs. Hirendra Pal Singh (2011)
5 SCC 305; Yashwant Sinha Vs. CBI (2020) 2 SCC 338; M/s Penna
Cement Industries Ltd. Vs. Joint Director, DoE, FPA- PMLA- 1190/
HYD/2016, decided by the Appellate Tribunal PMLA on 14.06.2019;
RKM Power Gen Pvt. Ltd. Vs. Directorate of Enforcement, decided by
the Madras High Court in WP no.4297 and 4300, 4807 and 4809 of
2025, decided on 15.07.2024; Sumed Singh Saini Vs. Devinder Pal
Singh Bhullar and Ors. (2011) 14 SCC 770.
7.1. None of those judgments help the case of accused at this stage of the
matter on the point of cognizance, and are all distinguishable on facts.
8. On the other hand, DoE relies on the following cases:
Soma
Chakravarty Vs. State (2007) 5 SCC 403; Chandra Deo Singh Vs.
Prakash Chandra Bose AIR 1963 SC 1430; Smt. Nagawwa Vs. Veerana
Shivalingappa Konjalgi (1976) 3 SCC 736; Shivjee Singh Vs.
Nagendra Tiwary and Ors. (2010) 7 SCC 578; Vijay Madan Lal
Chaudhary (supra); Pawna Dibbur Vs. DoE, Crl. Appeal no. 2779 of
2023, decided by the Supreme Court; P Rajenderan Vs. DoE, dated
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14.09.2022, by the Madras High Court in Crl. Original Petition no.
19880 of 2022; J. Sekar Vs. UoI 2018 SCC OnLine Del 6523;
Radhamohan Lakhotia Vs. DoE 2010 SCC OnLine Bom 1116; DoE Vs.
Aditya Tripathi 2023 SCC OnLine SC 619; Dr. Manik Bhattacharya Vs.
Ramesh Malik 2022 SCC OnLine SC 1465; and DoE Vs. Ashok Chand,
Crl. RC no. 1262/24, decided by the Madras High Court on
25.09.2024.
9. Having heard both sides and upon perusal of the complaint and
supporting material, this Court finds prima facie sufficient grounds to
proceed and take cognizance of the offences, as there are sufficient
grounds to proceed against the accused persons and entities for the
offence of money laundering under section 3 & 4 of the PMLA.
9.1. The accused’s argument regarding violation of Section 17A of the PC
Act, as to the bank officials, does not help at this stage of the matter, as
even if it is assumed that the said provision was violated qua the bank
officials, it would not affect the predicate offence against other non-
public servants. Nor would it affect the present PMLA complaint, which
does not involve bank officials.
9.2. The contention that CBI invoked Section 13(1)(d) of the PC Act, which
no longer exists in the statute book post 26.07.2018, also needs to be
rejected, as the case pertains to the period when the said provision was
in force, and therefore the law existing at the time of commission of the
offence shall govern the proceedings. It would be immaterial that
subsequently Section 13 underwent amendment and the offence of
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misconduct was redefined. When at the time of commission of the
predicate offence the said offence existed, the trial has to continue.
9.3. Mere non-compliance with the CVC/ABBF protocols as to referring the
fraud to ABBF cannot vitiate the present PMLA proceedings.
9.4. The law is settled that money laundering is a stand-alone offence,
distinct and independent of the scheduled offence, and it can be said not
to exist only when the accused is discharged or acquitted in the
predicate offence. The offence of money laundering has different
ingredients and objectives than the predicate crime. PMLA begins the
moment a person engages with proceeds of crime. The requirement in
law is only that there must exist a registered predicate offence which
can trigger a PMLA complaint. In this case, an FIR for the predicate
offence does exist, and even if it is under investigation, it can’t be
claimed that the PMLA complaint cannot be instituted or progressed
with.
9.5. In this regard, DoE also cites Section 44 of the PMLA, which clarifies
that a Special Court’s jurisdiction “shall not be dependent upon any
order passed in respect of the scheduled offence”. Also, Section 71 of
the PMLA gives an overriding effect over other laws. In this regard,
DoE also notes that the Financial Action Task Force (FATF)
recommendations do not require a conviction for a predicate offence to
prove that the property constitutes proceeds of crime. DoE also argues
that the amendments to Sections 17 and 18 of PMLA make clear that
PMLA actions have been de-linked from the predicate investigation
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timeline, and therefore, the requirement of a police report for
conducting searches has been removed. Citing the case of
DoE vs
Ashok Anand (Supra), the DoE highlights that once the ECIR is
registered, the connection between the ECIR and the FIR in the
predicate offence is severed, and the FIR loses its relevance, and the
ECIR becomes an independent document in itself.
9.6. Section 3 of the PMLA requires, beyond the existence of proceeds of
crime, that a money laundering offence be demonstrated through a
process involving placement, layering and integration, undertaken with
criminal intent. Placement involves introducing illicit funds into the
financial system. Layering involves creating complex transactions to
obscure the origin of the funds. Integration involves reintroducing the
laundered funds into the legitimate economy.
9.7. As per the judgment of the Hon’ble Supreme Court in the case of
Vijay
Madanlal Chaudhary (Supra), (Para 187(d)), the only requirement to
prosecute a person under PMLA is that a scheduled offence is registered
with the jurisdictional police and/or is pending enquiry/trial, including
by way of a criminal complaint before the competent forum. It is only
when no such case is registered, or the person is finally
discharged/acquitted of the scheduled offence, or the criminal case
against him is quashed by the Court of competent jurisdiction, that there
can be no offence of money laundering against him and others. The said
observation of the Hon’ble Supreme Court makes it clear that
cognizance on a PMLA complaint is not contingent upon filing of the
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charge sheet in the predicate offence or the Court taking cognizance of
the predicate offence.
9.8. The proceedings under the PMLA and the scheduled offence are distinct
and linked by the proceeds of crime until a person is acquitted or
discharged in the scheduled offence, or the scheduled offence FIR is
quashed by the competent Court. Therefore, the cognizance by a Special
Court is not prevented on the PMLA complaint while the scheduled
offence is still under investigation. The actual requirement is that the
scheduled offence must be registered or pending, rather than having
reached the specific stage of cognizance.
9.9. Arguments against the sufficiency or procedural aspects of the CBI’s
investigation in the predicate offence are irrelevant to the PMLA
proceedings. A PMLA trial is not dependent on the filing of a
chargesheet in the scheduled offence. The only condition that would
nullify the PMLA case is the final acquittal, discharge or quashing of
the scheduled offence against the accused. The legal spheres qua the
scheduled offence and the PMLA offence are separate, even though
factually related, as they have different ingredients, objects and
consequences. The existence of a registered FIR for the scheduled
offence is sufficient to confer jurisdiction, and there is no requirement
of a prior chargesheet in a predicate offence.
9.10. Thus, the status of the predicate case at this stage of the matter may be
irrelevant, and it is only when the accused is finally absolved in the
scheduled offence through acquittal, discharge, or quashing of the case
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that it can be claimed that the PMLA trial cannot proceed. Till then, the
PMLA trial can proceed independently.
9.11. The non-mentioning of the name of an accused in the scheduled offence
is also immaterial and irrelevant, and Section 3 of PMLA deals with
proceeds of crime by “any person”, regardless of whether that person is
named as an accused in the predicate case.
9.12. Qua the issue of territorial jurisdiction raised by the accused persons,
the DoE responds that this Court has jurisdiction because the SBLC
facility agreement was executed in New Delhi, the ECIR was registered
in New Delhi, and the related court orders were issued by the courts in
New Delhi. There is force in the contention of DoE and this Court is
satisfied that it does have territorial jurisdiction to try the present
complaint.
9.13. Qua the need for sanction u/s 218 of BNSS (corresponding to Section
197 of Cr.PC.), DoE responds that it applies only when a court takes
cognizance of an offence committed by a public servant in the discharge
of official duty, and that it does not bar the registration of an FIR or
investigation itself or cognizance against persons who were not public
servants as such.
9.14. In the present complaint bank officials are not accused, therefore there
is no public servant who can claim protection u/s 218 of BNSS, and the
said bar does not apply qua the accused/ entities against whom the
complaint has been filed. Even otherwise bar u/s 218 BNSS applies
only where the offence is alleged to have been committed by the public
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servant while acting or purporting to act in the discharge of his official
duty.
9.15. The accused persons’ plea for an in-depth scrutiny of the predicate case
is contrary to law. At this stage, the Court’s duty is limited to a prima
facie review of the complaint to determine whether it discloses an
offence and is prima facie sufficient to proceed. The legal threshold for
cognizance on a complaint is limited to establishing a prima facie case,
and the Court is not required to assess the probative value of evidence
or conduct a mini-trial. It is only required to determine whether
sufficient grounds exist to proceed.
9.16. The DoE’s complaint does outline a complex, multilayered scheme
orchestrated by the promoters of A-4 to divert the loan funds, with
layering, concealment, routing, and integration, as appearing prima
facie.
9.17. The defence's argument that no wrongful loss is caused to the banks is
premature, given the stage of the matter.
9.18. Whether or not the lender had prior knowledge about all credit facilities
sanctioned and utilized is again a matter of trial and cannot be
considered at the stage of cognizance.
9.19. Merely because the bank or lending institutions did not lodge a
complaint alleging fraud or criminality, it can’t be a ground to decline
cognizance.
9.20. It also can’t be said that there are no proceeds of crime, at least at this
stage of the matter. The factual arguments raised by the defence are
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better reserved for the appropriate stage of the matter, and, as mentioned
above, the discussion in the present order is confined to the limited
scope available before this Court in terms of taking cognizance, having
considered the submissions of the proposed accused/entities u/s 223 of
BNSS.
9.21. The argument of A-1 to A-3 as to no role is also not something that can
be considered at this stage.
9.22. Thus, there are sufficient grounds to proceed to take cognizance for
offence u/s 3 & 4 of PMLA and to proceed against the accused persons/
entities named in the complaint.
10. It may be mentioned here that the accused side claims that both the CBI
FIR and the DoE ECIR are currently challenged in a pending writ
petition No. 729 of 2023 filed by one Deepak Pendekar and V. N. Dhoot
(A-1) before the Bombay High Court. Vide an order dated 22.10.2024,
the Hon’ble Bombay High Court directed that no coercive steps be
taken against the proposed accused. Similarly, another writ petition
no.228/23 filed by one Nikhil Yadkikar, P.N. Dhoot (A-2), and Saurabh
Dhoot has been preferred before Hon’ble Delhi High Court, wherein
vide order dated 25.01.2023 Hon’ble Delhi High Court ordered that
subject to the petitioner’s joining and cooperating with the
investigation, no coercive action be taken against them.
10.1. A query was raised whether such interim order as to not adopting any
coercive process against the petitioners, which include two proposed
accused, can affect taking cognizance by this court. Arguing against it,
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18
Order dated 10.02.2026 in Ct. Case No. 32/2024; CNR No. DLCT11-001235-2024; Directorate of Enforcement (DoE) Vs. Venugopal
Nandlal Dhoot @ V. N. Dhoot & Ors.
Page 18/19
DoE claimed that in the writ petition no.228/2023 the order itself is
explicit that it was regarding protection to the petitioners from arrest
and the investigation was neither stayed nor curtailed in any manner. In
that petition the prayers were to quash the FIR registered by CBI and
the ECIR registered by PMLA, as to not arrest the petitioners and as to
not insist on physical appearance of the petitioners keeping in view
the health condition. Similarly, it is pointed out that the order in W.P.
(Crl.) 729/23 the interim protection was limited in scope linked to the
petitioner’s medical condition and apprehension of arrest. DoE, relying
upon the cases of
Puneet Vs. State and Anr. 2017 SCC OnLine Raj
4061; Neehaarika Infrastructure Pvt. Ltd. Vs. State of Maharashtra
2021 SCC OnLine SC 315; Vijay Madanlaal Chaudhary (supra); and
the case of Satya Prakash Bagla Vs. State and Ors. Crl. MC no.
103/2025 decided by Hon’ble DHC on 13.11.2025, argues that the
interim protection of “no coercive action” is limited to the arrest or
physical appearance of the petitioners and neither stay to the
investigation nor bar against taking cognizance.
10.2. This Court finds force in the argument of DoE on this aspect of the
matter also especially in the light of the specific prayers made by the
petitioners in those writ petitions and also in the light of the judicial
pronouncements in the above mentioned cases.
11. Resultantly the objections raised by the proposed accused persons/
entities from taking cognizance of the offence, within the limited
confines of Section 223 of BNSS, stands rejected. Finding sufficient
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19
Order dated 10.02.2026 in Ct. Case No. 32/2024; CNR No. DLCT11-001235-2024; Directorate of Enforcement (DoE) Vs. Venugopal
Nandlal Dhoot @ V. N. Dhoot & Ors.
Page 19/19
material to proceed for offences u/s 3 & 4 of PMLA, cognizance of
those offences is taken against the proposed accused persons/ entities.
Summons be issued to the accused persons and entities.
Announced in the open Court
on 10th February 2026
DIG VINAY SINGH
SPECIAL JUDGE (PC ACT), CBI-09
(MPs/MLAs CASES), RADC, NEW DELHI
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