SC of India
2026 INSC 702
2026 INSC 702
14 July 2026 ★
Amit Katyal vs Union of India
WP (Crl.) No. 57/2026 — PMLA transfer case
Background
- Katyal = promoter of Krrish Realtech Pvt. Ltd. — project “Krrish World”, Gurugram
- Homebuyers allegedly cheated → 6 FIRs registered against Krrish & directors
- ECIR/GNZO/04/2023 (03.03.2023) registered on this basis
- Orig. prayer: quash Prosecution Complaint No. COMA/16/2025
- → narrowed at hearing to: transfer case Gurugram → Delhi
Why ED said “don’t quash”
- New scheduled offence found: FIR 439/2024 (EOW Gurugram) — 120B/406/409/411/420/471 IPC
- Linked to earlier FIR 30/2019, EOW Delhi (partly quashed, 406/120B still pending)
- So ECIR / prosecution not without jurisdiction
Why transfer to Delhi was allowed
★ Coordinate Bench already clubbed FIR 439/2024 with FIR 30/2019
& sent it to Delhi (18.05.2026, clarified 21.05.2026)
★ Part of “proceeds of crime” — cash, jewellery, vehicles, FDs — seized/attached at Delhi itself
★ Rest of proceeds (land) attached at Gurugram
★ Part of “proceeds of crime” — cash, jewellery, vehicles, FDs — seized/attached at Delhi itself
★ Rest of proceeds (land) attached at Gurugram
- S.44 PMLA + S.178(d) CrPC → offence spread over diff. areas ⇒ either court has jurisdiction
- Distinguished KA Rauf Sherif (2023) 6 SCC 92 — facts different, no clubbing there
- Relied on Rana Ayyub (2023) 4 SCC 357 — proceeds of crime & jurisdiction test
Held ✔
- PMLA case transferred: Special Judge PMLA, Gurugram → Special Judge PMLA, Saket Court Complex, Delhi
- Trial continues from same stage — no fresh start
- Writ petition disposed of
— Bench: CJI Surya Kant & Joymalya Bagchi, J. (Non-Reportable)
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