Appreciation in Assets from Criminal Funds Also ‘Proceeds of Crime’: Delhi High Court

The Delhi High Court ruled that any appreciation in the value of shares or assets derived from criminal activity constituted “proceeds of crime” under the Prevention of Money Laundering Act, 2002.

The Court held that the Enforcement Directorate could attach such gains even if the increase resulted from market or economic factors.

The case arose from falsified financial data used to secure a coal block allocation, leading to profits through preferential share allotment.

The Court observed that once criminally acquired funds were invested in shares, the entire appreciated value remained liable for attachment.

[Directorate of Enforcement v M/s Prakash Industries Ltd]