P. Jose Kunjippalu Vs Deputy Director (Appellate Tribunal under SAFEMA, New Delhi)
No Bribe Allegation Needed: Disproportionate Assets Can Themselves Trigger PMLA, SAFEMA Tribunal Upholds ₹1.01 Crore Attachment
Summary: The appellant, P. Jose Kunjippalu, was a public servant who worked as Assistant Commissioner of Income Tax, Circle-1, Palakkad Range. The CBI registered FIR No. RC 16(A)/2014 on 26 November 2014 alleging commission of an offence u/s 13(2) r.w.s. 13(1)(e) of the Prevention of Corruption Act, 1988.
According to the CBI, during the relevant check period, the appellant’s known income was ₹1,07,41,168, while he & his wife acquired properties worth ₹1,46,03,843 & incurred expenditure of ₹62,09,946. The alleged disproportionate assets were quantified at ₹1,00,72,621, representing 93.78% of the known lawful income.
Based on the scheduled offence disclosed in the CBI FIR, the ED registered an ECIR, conducted investigation & recorded statements u/s 50(2) & 50(3) of PMLA. It issued a PAO on 30 March 2022, attaching properties to the extent of the alleged proceeds of crime. The Adjudicating Authority confirmed the attachment on 7 September 2022.
The Tribunal had earlier disposed of the appeal on 17 March 2025. The Bombay High Court set aside that order on 10 June 2026 & permitted the appellant to seek reconsideration or expungement of observations. The Tribunal therefore heard the appeal afresh on merits.
