Chandra Mohan Jha Vs Deputy Director (Appellate Tribunal Under SAFEMA Delhi)
Fake Degrees Scam: Personal Properties Liable for Attachment as Proceeds of Crime – SAFEMA Tribunal Upholds PMLA Action
The Appellate Tribunal under SAFEMA, New Delhi in a batch of appeals led by Shri Chandra Mohan Jha & Ors. vs. Deputy Director, Directorate of Enforcement, Delhi (FPA-PMLA-7143 & 7148 to 7158/DLI/2023, final order dated 10-12-2025) dismissed all appeals and upheld confirmation of the Provisional Attachment Order (PAO) under the Prevention of Money Laundering Act, 2002.
The case arose out of the CMJ University fake degree scam, where FIR was registered by CID, Meghalaya (26-04-2013) for large-scale issuance of fake Bachelors’, Masters’, M. Phil & Ph. D degrees, even prior to commencement of university operations and courses, in gross violation of UGC regulations. Investigation revealed issuance of 20,570 fake degrees and generation of proceeds of crime amounting to ₹83.52 crore. ECIR was recorded on 07-07-2014, followed by attachment of movable & immovable properties worth about ₹13.54 crore.
The appellants contended that:
- No forged degree was physically recovered
- Personal properties had no nexus with the alleged offence
- Actual receipts were only ₹45 crore as per bank statements
Rejecting these arguments, the Tribunal held that:
