IBC and PMLA operate in distinct fields; NCLT cannot quash Enforcement Directorate attachment orders, and challenge lies elsewhere.

The NCLT held that it had no jurisdiction under the Insolvency and Bankruptcy Code, 2016 to quash or set aside an attachment of a corporate debtor's property made by the Enforcement Directorate under the Prevention of Money Laundering Act, 2002. It reasoned that PMLA proceedings operate in a distinct field, that the Tribunal is not a forum for judicial review of Enforcement Directorate orders, and that insolvency provisions do not confer power to annul such an attachment. Any challenge to the attachment, if available, lies before the authority that issued the order or its appellate forum. The application was therefore not maintainable.

---

---

Issues: Whether the National Company Law Tribunal had jurisdiction under the Insolvency and Bankruptcy Code, 2016 to quash or set aside attachment of the corporate debtor's property made by the Enforcement Directorate under the Prevention of Money Laundering Act, 2002, and whether the moratorium or other insolvency provisions barred such attachment.

Analysis: The application sought relief against a provisional attachment confirmed under the Prevention of Money Laundering Act, 2002 after initiation of corporate insolvency resolution process. The Tribunal noted that the controversy centered on the interface between the two special statutes. Relying on judicial authorities, it held that proceedings under the Prevention of Money Laundering Act, 2002 operate in a distinct field, that the Tribunal is not a forum for judicial review of orders passed by the Enforcement Directorate, and that the insolvency provisions invoked by the applicant do not confer power to annul an attachment made under the money-laundering law. The Tribunal further held that the applicant's grievance, if any, lies before the authority that passed the order or its appellate forum.

Conclusion: The Tribunal held that it had no jurisdiction to quash or set aside the attachment order under the Prevention of Money Laundering Act, 2002, and the application was not maintainable.

---