Provisional attachment under money-laundering law is not extended by COVID limitation orders, and separate adjudication may continue independently.

COVID-19 limitation-extension orders did not extend the fixed 180-day subsistence period of a provisional attachment under Section 5(1) of the Prevention of Money-Laundering Act, because that period is a substantive statutory lifespan rather than a filing limitation. The attachment therefore expired on its own timeline. Quashing the provisional attachment did not automatically bring Section 8 adjudication proceedings to an end, since adjudication is a separate statutory process proceeding independently on its own merits. The challenge to the attachment could succeed, but consequential relief could not be treated as automatic where the adjudicatory stage remained legally distinct and capable of continuing in accordance with law.

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Issues: (i) Whether the COVID-19 limitation-extension orders applied to extend the 180-day validity period of a provisional attachment order under Section 5(1) of the Prevention of Money-Laundering Act, 2002. (ii) Whether quashing the provisional attachment order necessarily brought the adjudication proceedings under Section 8 of the Prevention of Money-Laundering Act, 2002 to an end.

Issue (i): Whether the COVID-19 limitation-extension orders applied to extend the 180-day validity period of a provisional attachment order under Section 5(1) of the Prevention of Money-Laundering Act, 2002.

Analysis: The provisional attachment under Section 5(1) operates for a fixed statutory period and ceases to have effect on expiry of that period or on an order under Section 8(3), whichever is earlier. The limitation-extension orders passed during the pandemic were directed to petitions, applications, suits, appeals, and similar proceedings where a party was required to seek legal remedy within time. They were not intended to alter the subsistence period of a statutory attachment order. The validity period under Section 5(1) is not a filing limitation but a substantive lifespan of the attachment.

Conclusion: The extension orders did not extend the validity period of the provisional attachment, and the attachment had expired on the statutory timeline.

Issue (ii): Whether quashing the provisional attachment order necessarily brought the adjudication proceedings under Section 8 of the Prevention of Money-Laundering Act, 2002 to an end.

Analysis: The adjudication under Section 8 is a separate statutory process that proceeds on its own merits. Quashing of the provisional attachment under Section 5(1) does not automatically nullify the adjudicatory proceedings. The two stages are distinct in scheme and effect, and success on the challenge to provisional attachment does not by itself terminate the proceedings before the adjudicating authority.

Conclusion: The provisional attachment could be set aside, but the Section 8 proceedings were not liable to be treated as as a consequence of that setting aside.

Final Conclusion: The challenge to the provisional attachment succeeded, but the blanket grant of consequential relief was unsustainable because the adjudication process remained independent and could continue in accordance with law.

Ratio Decidendi: A statutory provisional attachment governed by a fixed period is not extended by general COVID-19 limitation orders, and quashing such attachment does not automatically extinguish independent adjudication proceedings under the Act.

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