Anand Chauhan Vs Deputy Director (Appellate Tribunal Under Safema At Delhi)
Sweet Apples, Sour Truth – Tribunal Confirms ₹11.41 Lakh PMLA Attachment for LIC Agent Linked to Virbhadra Singh
The Appellate Tribunal under SAFEMA, New Delhi, in its Final Order dated 14.10.2025, dismissed the appeal [FPA-PMLA-3165/DLI/2019] filed by Anand Chauhan, LIC agent and co-accused in the disproportionate assets case of Virbhadra Singh, challenging the attachment of his 68% share in “Kailash Niwas,” Shimla (₹11.41 lakh) under the Prevention of Money Laundering Act, 2002 (PMLA).
The Enforcement Directorate (ED) found that Chauhan, who managed Shrikhand Orchards (HUF of Virbhadra Singh), deposited large amounts of unaccounted cash into his accounts, procured LIC policies for Singh’s family, and attempted to misrepresent orchard income through fabricated documents. The Tribunal rejected Chauhan’s claim that the commission was genuine LIC earnings, citing forged stamp papers, fake transport records, and cash layering activities.
Relying on the Supreme Court judgment in Vijay Madanlal Choudhary, the Tribunal affirmed that money-laundering is a continuing offence, and PMLA applies even if the predicate offences occurred before the 2013 amendment. It also followed Prakash Industries v. ED (Delhi HC) to confirm that property of equivalent value can be attached if tainted funds have been spent.
The Tribunal concluded that Chauhan actively assisted in laundering ₹11.41 lakh and upheld the ED’s attachment, ruling that the property represents the “value of proceeds of crime.”
Result: Appeal dismissed; attachment of property confirmed (Order dated 14.10.2025).
FULL TEXT OF THE JUDGMENT/ORDER OF APPELLATE TRIBUNAL UNDER SAFEMA AT DELHI
