Manik Bhattacharya Vs Deputy Director (Appellate Tribunal Under SAFEMA Delhi)
SAFEMA Tribunal Upholds PMLA Attachment in West Bengal TET Scam; Rejects Manik Bhattacharya’s Appeals
The Appellate Tribunal under SAFEMA dismissed the appeals filed by Dr. Manik Bhattacharya, his son Souvik Bhattacharya, and his wife Satarupa Bhattacharya, upholding the confirmation of attachment of properties worth ₹7.93 crore under the Prevention of Money Laundering Act (PMLA). The attachment arose from the alleged West Bengal TET-2014 recruitment scam, in which the Enforcement Directorate (ED) alleged that proceeds of crime generated through illegal selection of candidates and extortion from D.El.Ed. colleges and students were laundered through multiple bank accounts, fixed deposits, mutual funds and other investments.
The Tribunal rejected the appellants’ contention that they were not accused in the predicate offence, noting that Manik Bhattacharya had been chargesheeted, charges had been framed against him, and his discharge application had already been dismissed. It also held that the appellants had misread the Calcutta High Court’s 2025 judgment concerning cancellation of appointments of 32,000 primary teachers, observing that the High Court decision related to the 2016 recruitment process, whereas the present PMLA proceedings concerned alleged corruption in the TET-2014 eligibility examination. The Tribunal found no merit in the argument that the High Court judgment exonerated the appellants.
The Tribunal further held that the ED had sufficient material to record “reasons to believe” under Section 5 of the PMLA before attaching the properties. It observed that the investigation revealed multiple bank accounts, substantial cash deposits, routing and layering of funds, and evidence linking the appellants to alleged proceeds of crime through witness statements, digital evidence and financial records. It also noted that the appellants failed to satisfactorily explain the source of substantial cash deposits despite the statutory burden under Sections 8 and 24 of the PMLA. Accordingly, the Tribunal found the provisional attachment and its confirmation by the Adjudicating Authority to be legally sustainable and declined to interfere with the impugned order.
FULL TEXT OF THE JUDGMENT APPELLATE TRIBUNAL UNDER SAFEMA AT NEW DELHI
