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Welcome to the July 2026 edition of our White-Collar Crime & Investigations Newsletter. This month saw significant enforcement activity across India’s regulatory landscape, with the Directorate of Enforcement (ED) continuing its aggressive asset recovery efforts and several important judicial pronouncements clarifying procedural rights under the Prevention of Money Laundering Act, 2002 (PMLA) and Bharatiya Nagrik Suraksha Sanhita (BNSS). We also highlight notable international developments that may be of interest to clients with cross-border operations.
Enforcement Action
Directorate of Enforcement
Mahadev Betting Probe: ED attaches additional ₹940.77 crore against Mr. Vikas Garg
On 10 July 2026, the ED’s Raipur Zonal Office provisionally attached assets worth approximately ₹940.77 crore belonging to businessman Vikas Garg, his family members, and related entities under the PMLA. According to the ED, the betting syndicate operated through a franchise-based panel network managed from overseas, allegedly generating proceeds of crime exceeding ₹450 crore per month through illegal betting activities. The attached assets include residential properties, land, shares, and other securities linked to alleged proceeds of crime from the Mahadev Online Book and Sky Exchange betting network, which were purportedly routed through shell entities and layered transactions before being invested in companies associated with Mr. Garg. This marks the seventh attachment order in the case, taking the total value of assets attached, seized, or frozen to nearly ₹3,800 crore.
ED's attachment tally in Reliance ADA group crosses ₹20,367 crore, as fresh ₹1,021 crore PAO deepens scrutiny of RHFL/RCFL fund diversion
The ED has attached assets worth ₹1,021 crore under the PMLA in connection with its investigation into Reliance Home Finance Ltd. (RHFL) and Reliance Commercial Finance Ltd. (RCFL). The probe, initiated based on multiple FIRs registered by the CBI following complaints from several public and private sector banks, alleges that public funds amounting to ₹15,548 crore were diverted through a network of shell and group companies linked to the Reliance Anil Ambani Group. With this attachment, the total value of assets attached in Reliance Anil Ambani Group-related cases under the PMLA has reached ₹20,367 crore. The ED has also attached assets worth ₹77.86 crore under the Foreign Exchange Management Act, 1999 (FEMA), conducted searches at over 80 locations, and arrested eight senior officials and close associates of the group, all of whom remain in judicial custody.
ED Raids eight Bengaluru locations over alleged ISIS recruitment and terror-funding network
On 21 July 2026, the ED’s Bengaluru Zonal Office conducted searches at eight locations in Bengaluru as part of a money laundering investigation linked to an alleged ISIS recruitment and terror financing module. During the searches, the ED seized electronic records and digital devices and froze proceeds of crime amounting to ₹7.5 lakh under the PMLA. The investigation stems from an Enforcement Case Information Report (ECIR) based on a National Investigation Agency (NIA) case relating to alleged ISIS recruitment activities. According to the NIA, the accused were allegedly involved in a conspiracy to radicalize and recruit youth for the banned terrorist organisation ISIS and to raise funds to facilitate their travel abroad.
West Bengal SSC Recruitment Scam widens: ED files second supplementary prosecution complaint against Partha Chatterjee and others
The ED’s Kolkata Zonal Office has filed its second supplementary prosecution complaint before the Special PMLA Court, Kolkata, in connection with the West Bengal Central School Service Commission Teacher Recruitment Scam. The complaint names former West Bengal Education Minister Partha Chatterjee and others. The investigation, originating from FIRs registered by the CBI, relates to widespread irregularities in the recruitment of Assistant Teachers in Classes IX-X and XI-XII. The ED alleges that Mr. Chatterjee facilitated the scheme in collusion with officials and intermediaries in exchange for undue benefits. The agency has attached assets worth ₹301.58 crore in this case and a total of ₹702.93 crore across related recruitment scam investigations. Notably, in April 2025, the Supreme Court of India upheld the cancellation of over 25,000 teaching and non-teaching appointments, citing serious irregularities that had compromised the integrity of the recruitment process.
Central Bureau of Investigation (CBI)
CBI files first chargesheet in Reliance Commercial Finance Ltd. (RCFL) case
On 7 July 2026, the CBI filed its first chargesheet before the Special Judge for CBI, Mumbai in connection with alleged fund diversion by RCFL. The chargesheet names seven accused, including Reliance Infrastructure Ltd., RHFL, and five former senior RCFL executives. According to the CBI, funds borrowed by RCFL were allegedly routed through intermediary entities to Reliance ADA Group companies in violation of lending terms, resulting in an estimated loss of ₹4,097 crore to a consortium of 13 public sector banks. The case originated from complaints filed by Bank of Maharashtra and other public sector banks in the lending consortium for an estimated loss at ₹4,097 Crores.
Source: Press Information Bureau
CBI conducts searches in West Bengal, Odisha, Tamil Nadu, and Uttarakhand in ₹1,109 crore bank fraud case
The CBI has conducted searches across six locations in West Bengal, Odisha, Tamil Nadu, and Uttarakhand in connection with a bank fraud case involving M/s Gupta Power Infrastructure Ltd., Bhubaneswar, Odisha. The case relates to an alleged ₹1,109 crore fraud on Canara Bank through fund-based and non-fund-based credit facilities. According to the CBI, the company and its directors allegedly inflated stock values and trade receivables, falsified financial statements to secure enhanced credit limits, diverted loan funds, and engaged in evergreening of accounts, resulting in significant losses to the bank.
Source: Central Bureau of Investigation
Latest case laws
Supreme Court of India
SFIO Proceedings Against Vivo India stayed by the Supreme Court of India
The Supreme Court of India in Vivo Mobile India Pvt. Ltd. v. Serious Fraud Investigation Office, S.L.P. (Crl.) No. 13088/2026 has stayed further proceedings in an SFIO prosecution against Vivo India Pvt. Ltd. and issued notice on the petition challenging the Punjab & Haryana High Court’s ruling on the applicability of the first proviso to Section 223 of the BNSS in proceedings arising out of the Companies Act, 2013.
Before the Punjab & Haryana High Court, the case arose from a challenge to the Special Court’s denial of a hearing against the complaint lodged by SFIO alleging that Vivo India and certain associated entities committed fraud exceeding ₹2,000 crore through the falsification of books of account and financial statements. Vivo contended that it was entitled to a mandatory pre-cognizance hearing under the first proviso to Section 223 of the BNSS before the Special Court could take cognizance of the complaint. The Supreme Court has now agreed to examine the issue, as such a right to a hearing has broader implications for the procedural rights of companies facing prosecution under special statutes.
Supreme Court holds that prosecution sanction once refused cannot be reconsidered without fresh evidence
The Supreme Court of India in State of Rajasthan v. Dev Kant Meena, S.L.P. (Crl.) No. 2951/2026 held that a decision refusing sanction to prosecute a public servant under Section 19 of the Prevention of Corruption Act, 1988 (PC Act) cannot be reviewed or reconsidered based on the same material that was previously examined. The Court reiterated that a mere change of opinion by the competent authority is insufficient to justify revisiting an earlier decision unless new and relevant evidence emerges. The Court observed that the reconsideration in the instant case reflected a lack of independent application of mind and criticized the reopening of the matter on identical facts. The appeal was dismissed with costs, with the Court observing that when two views are possible, the one favoring the public servant should ordinarily be adopted.
Section 175(4) BNSS: Superior's report mandatory if offence allegedly committed during discharge of official duties
The Supreme Court of India in XXX v. State of Kerala, Crl. Appl. 4629/2025 has held that Section 175(4) of the BNSS is not a standalone provision but an additional procedural safeguard for public servants accused of acts performed in the discharge of official duties. The Court observed that where a Magistrate is prima facie satisfied that the alleged offence has a reasonable nexus with official functions, a report from the public servant’s superior officer must be called for and considered before directing an investigation. The Court further held that a complaint under Section 175(4) should be in writing and supported by an affidavit.
High Courts
Delhi High Court declines request for disclosure of MCA investigation orders in SFIO probe involving Anil Ambani Group companies
The Delhi High Court in Mandke Foundation v. Union of India, W.P. (C) No. 10462/2026 has declined to direct the Ministry of Corporate Affairs (MCA) and the SFIO to disclose orders authorizing an investigation into Reliance Home Finance Ltd., Reliance Communications Ltd., and other Anil Ambani Group companies. The Court held that the petitioner, Mandke Foundation, had no enforceable right to seek disclosure of the investigation orders or the underlying material while the SFIO investigation remained at a preliminary stage. The Court observed that the SFIO's notice had adequately informed the Petitioner of the nature and purpose of the inquiry and accepted the authorities' contention that disclosure of the MCA orders could prejudice the ongoing investigation and related proceedings.
Chhattisgarh High Court refuses UAE travel plea of PMLA accused, cites lack of medical necessity
The Chhattisgarh High Court in Sunil Kumar Agrawal v. Directorate of Enforcement, C.R.M.P. 1534/2026 refused to permit a petitioner facing prosecution under the PMLA to travel to Abu Dhabi for medical treatment. The petitioner had sought permission to undergo KKT therapy for a hamstring injury, contending that the specialized treatment was unavailable in India and could help him avoid surgery. Upholding the Special Court's order, the Court held that “personal preference cannot be equated with absolute medical necessity” and observed that an accused cannot insist on treatment abroad when comparable medical facilities are available domestically.
PMLA proceedings are distinct from predicate offence trial; double jeopardy not attracted: Karnataka High Court
The Karnataka High Court in Dilip A. & Ors. v. Assistant Director, Enforcement Directorate, Crl. P. 748/2025 has held that prosecution under the PMLA following conviction in the predicate offence does not attract the constitutional protection against double jeopardy. The Court observed that money laundering is a distinct and independent statutory offence, and proceedings under the PMLA cannot be treated as a second trial for the same offence merely because they arise from the same underlying facts.
The petitioners, who had been convicted in a demonetization-related predicate offence involving the exchange of old currency notes for new notes at a premium, sought quashing of the PMLA proceedings on the ground that they amounted to a second prosecution. Rejecting the challenge, the Karnataka High Court held that Section 300 of the Code of Criminal Procedure, 1973 (CrPC) bars only a subsequent trial for the same offence and not prosecution under a separate statutory framework with distinct ingredients.
Appellate Tribunal under SAFEMA at New Delhi
Appellate Tribunal under SAFEMA sets aside ED's ₹16.13 crore attachment in Unitech-linked matter
The Appellate Tribunal under SAFEMA in M/s. Sahana Builders and Developers Private Limited v. Deputy Director, Directorate of Enforcement, Mumbai, FPA-PMLA-946/MUM/2025 set aside the ED’s attachment of a fixed deposit worth ₹16.13 crore belonging to Sahana Builders and Developers Pvt. Ltd., holding that a ₹10 crore payment received from Unitech Ltd. in 2004 arose from a genuine commercial transaction and could not be classified as “proceeds of crime.” The Tribunal noted that the payment was made for the proposed purchase of 11 shops and predated the alleged period during which funds were diverted from homebuyers by Unitech.
Allowing the appeal, the Tribunal observed that attachment of equivalent-value property under the PMLA requires a clear nexus with proceeds of crime, which was absent in the present case. It held that the ED could not invoke the PMLA to effectively recover amounts allegedly due to Unitech from a transaction that occurred before the alleged money laundering activity began.
Global Enforcement Roundup
Dutch prosecutors initiate criminal proceedings against Tata Steel IJmuiden over alleged pollution
The Dutch Public Prosecution Service (Openbaar Ministerie) has initiated criminal proceedings against Tata Steel IJmuiden, the Netherlands-based subsidiary of Tata Steel, alleging the intentional and unlawful release of harmful substances into the air from its steel manufacturing facility in IJmuiden. According to Dutch prosecutors, the company allegedly failed to adequately maintain parts of its steel production process and did not report several incidents involving emissions of raw coke, a by-product generated during steel production. The company has been summoned to appear before the Amsterdam District Court on 20 November 2026, where the specific charges will be formally presented.
The investigation was launched in 2022 following complaints filed on behalf of around 800 residents and several organizations, alleging that emissions from the plant posed risks to public health. Dutch authorities are also examining whether individual company managers may bear personal liability for the alleged violations. The company has indicated that it will contest the allegations and present its defense during the court proceedings. This follows an earlier 2023 environmental law conviction in which the company was ordered to pay a fine of €110,000 in a separate waste disposal matter.
Public Prosecution Service sues Tata Steel | Public Prosecution Service
US Judge dismisses criminal cases against Gautam Adani, Sagar Adani, and others
U.S. Federal Judge Nicholas Garaufis dismissed the criminal fraud and bribery case against Indian billionaire Gautam Adani after the Department of Justice (DOJ) decided to drop the prosecution. Judge Garaufis reviewed the reasons behind the government's decision, including concerns about whether Adani's earlier pledge to invest $10 billion in the U.S. influenced the outcome, and concluded that the investment commitment did not play a role in the dismissal. However, the Judge criticized the DOJ's handling of the case, noting “troubling irregularities” in the decision-making process. He specifically questioned the role of senior DOJ official Trent McCotter, who worked with Adani's defense team while reportedly not consulting the prosecutors and investigators who built the case. Despite approving the dismissal, Judge Garaufis stressed that this ruling should not be seen as an endorsement of the DOJ's decision or a judgment on the merits of the allegations.
Source: U.S. District Court, Eastern District of New York: DOJ dismissal memo and order
French Anti-Corruption Agency imposes first-ever monetary penalty for compliance failures
France's Anti-Corruption Agency (AFA) has, for the first time, imposed a direct financial penalty instead of issuing a compliance injunction for deficiencies in an anti-corruption compliance programme. The AFA's Sanctions Committee levied a fine of €350,000 on an unnamed company and €60,000 on its director for failing to implement seven of the eight anti-corruption compliance measures required under France's Sapin II law. According to the AFA, the company lacked key compliance mechanisms, including an enterprise-wide corruption risk assessment, anti-corruption training for high-risk employees, effective monitoring systems, adequate accounting controls, and robust third-party due diligence procedures.
While the AFA acknowledged that the company had undertaken significant remedial measures, it noted that these efforts occurred only after regulatory intervention and that the compliance deficiencies had persisted since 2017. The decision marks a significant development in the enforcement of France's anti-corruption framework and signals a more stringent approach toward corporate compliance failures.
Source: French Anti-Corruption Agency (AFA): Décision commission des sanctions Affaire Société V. et M. S.
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