Chain of title and registered documents prevailed for one property claim, while unproved ownership defeated relief over two plots.

A clear and consistent chain of title supported by registered documents, earlier ownership records and site particulars will displace a later disputed transaction for PMLA purposes. On the facts, Urmil Gupta established lawful title to plot no. 47 because her sale deed was traced through prior conveyances and matching boundary details, so the property was excluded from restraint. Mahavir Singh Saini, however, did not prove completed ownership in plots no. 47 and 48: the agreements to sell were unsupported by full payment, a sale deed, or proof of how title passed to his vendors, so his claim failed and no relief was granted against attachment or freezing.

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Issues: (i) Whether plot no. 47 at Ashoka Park Extension was validly established as the appellant Urmil Gupta's property and wrongly included in the PMLA proceedings. (ii) Whether appellant Mahavir Singh Saini established a lawful title or enforceable ownership interest in plots no. 47 and 48 so as to warrant exclusion from the impugned order.

Issue (i): Whether plot no. 47 at Ashoka Park Extension was validly established as the appellant Urmil Gupta's property and wrongly included in the PMLA proceedings.

Analysis: The sale deed in favour of Urmil Gupta was supported by earlier title documents, a registered conveyance, consistent boundary details, and the layout plan showing plot no. 47 as measuring 416.5 sq. yds. The materials produced by the appellant coherently traced title to the pre-existing ownership chain, while the alleged 2015 sale deeds relied upon by the enforcement authorities lacked a satisfactory chain of title, did not explain how the plot number was assigned, and were inconsistent with the established site particulars. On the facts, the property claimed by Urmil Gupta was treated as a genuine and distinct property, not shown to be part of the alleged fraudulent transaction.

Conclusion: The appellant Urmil Gupta succeeded in establishing her title to plot no. 47, and the property was directed to be excluded from the impugned restraint.

Issue (ii): Whether appellant Mahavir Singh Saini established a lawful title or enforceable ownership interest in plots no. 47 and 48 so as to warrant exclusion from the impugned order.

Analysis: The documents relied upon by Mahavir Singh Saini did not show completed ownership in his favour. The agreements to sell remained unaccompanied by proof of full payment or execution of a sale deed, and the record did not establish how plot numbers 47 and 48 were carved out of the alleged khata or how title passed to his vendors in the manner asserted. In the absence of a perfected title, and with the chain of ownership remaining unproven, no basis was found to interfere with the attachment or freezing qua his claim.

Conclusion: The claim of Mahavir Singh Saini was rejected, and no relief was granted in respect of plots no. 47 and 48.

Final Conclusion: The impugned order was modified only to the extent of recognising Urmil Gupta's ownership claim over plot no. 47, while the challenge raised by Mahavir Singh Saini failed for want of proved title.

Ratio Decidendi: Where a claimant establishes a clear and consistent chain of title supported by registered documents and site particulars, the property cannot be treated as an alleged proceeds of crime merely on the basis of a later disputed transaction lacking a proven ownership chain.

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