Benami proceedings cannot survive for transactions completed before the 2016 amendment, following Ganpati Dealcom.

Proceedings under the amended benami regime could not be sustained where the underlying transactions were admittedly completed before 25 October 2016. Following the Supreme Court's ruling in Ganpati Dealcom and an earlier Bombay High Court view, the Court found no basis to uphold the provisional attachment, reference, or confiscation proceedings on those admitted facts. The impugned attachment and connected proceedings were therefore quashed.

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Issues: Whether the provisional attachment, reference and confiscation proceedings under the Prohibition of Benami Property Transactions Act, 1988 could be sustained where the underlying transactions were admittedly prior to 25 October 2016 and the Supreme Court had quashed similar proceedings in Ganpati Dealcom.

Analysis: The transaction dates were admitted to be prior to the coming into force of the Benami Transactions (Prohibition) Amendment Act, 2016. The Court followed the approach adopted in an earlier decision quashing similar benami proceedings in light of the Supreme Court's ruling in Ganpati Dealcom, and found no reason to take a different view on the admitted facts.

Conclusion: The impugned provisional attachment and connected proceedings were quashed, and the petition was allowed.

Ratio Decidendi: Proceedings under the amended benami regime cannot be sustained in respect of transactions admittedly completed before the amendment came into force.

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