Proceeds of crime doctrine bars a subsequent purchaser from defeating confirmed attachment under the PMLA.

Property derived from transactions linked to the scheduled offence was treated as proceeds of crime under the PMLA, so a subsequent purchaser could not claim a better title than the transferor. A sale effected during pending attachment proceedings did not remove the asset's tainted character, particularly where the transfer appeared unsupported by credible arm's length dealing, involved inter-connected parties, was below valuation, and occurred amid enforcement action. The availability of a remedy before the Special Court for a genuine claimant also weighed against interference. The challenge to the confirmed attachment therefore failed, and the property remained attached.

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Issues: Whether the subsequent purchaser was entitled to challenge the confirmation of attachment of the property on the plea of bona fide purchase and prior sale for valuable consideration, and whether the property retained its attachable character as proceeds of crime under the PMLA.

Analysis: The property was found to have originated from transactions linked to the scheduled offence and was treated as proceeds of crime under the PMLA. A transferee from such property could not obtain a better title than the transferor, and a subsequent sale during the pendency of attachment proceedings did not purge the tainted character of the asset. The transfer was viewed as lacking credibility as a genuine arm's length transaction, particularly in light of the inter-connected dealings between the groups, the timing of the transfer, the below-valuation consideration, and the pendency of enforcement action. The availability of a remedy before the Special Court under the PMLA for a genuine claimant also weighed against interference with the confirmed attachment.

Conclusion: The challenge to the confirmed attachment failed, and the property remained attached against the appellants.

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