Complete title chain required to defeat PMLA restraint; genuine ownership proved for one plot, but agreement-to-sell claim failed.

A claimant seeking release of property from PMLA restraint must establish a credible and complete chain of title. On the materials, Urmil Gupta's title to Plot No. 47 was accepted because her sale deed was supported by earlier conveyance and transfer documents, and the site-plan particulars matched the locality; the property was therefore directed to be released from attachment/freeze, subject to the pending civil suit. Mahavir Singh Saini's claim to Plot Nos. 47 and 48 failed because the agreements to sell did not culminate in registered conveyances, payment and transfer were incomplete, and the title chain was not proved. His challenge to the freezing confirmation was rejected.

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Issues: (i) Whether the appellant Urmil Gupta established a genuine title to Plot No. 47 at Ashoka Park Extension so as to merit exclusion of the property from PMLA action. (ii) Whether the appellant Mahavir Singh Saini had a valid enforceable title or possession interest in Plot Nos. 47 and 48 so as to challenge the freezing and confirmation order.

Issue (i): Whether the appellant Urmil Gupta established a genuine title to Plot No. 47 at Ashoka Park Extension so as to merit exclusion of the property from PMLA action.

Analysis: The sale deed relied upon by Urmil Gupta was supported by a prior chain of documents, including earlier conveyance and transfer instruments, and the plot boundaries and site-plan particulars matched the layout of the locality. The rival sale deeds in favour of the accused were found doubtful because they did not disclose the source of title of the vendors, the directional particulars of the property, or a proper chronological chain showing how Plot No. 47 came to be conveyed. The Tribunal accepted the appellant's version that the property was distinct from the property claimed through the later transactions and found her title to be genuine on the materials placed before it.

Conclusion: The issue is answered in favour of Urmil Gupta. Plot No. 47 was held to be her property and was directed to be released from the PMLA attachment/freeze, subject to the pending civil suit.

Issue (ii): Whether the appellant Mahavir Singh Saini had a valid enforceable title or possession interest in Plot Nos. 47 and 48 so as to challenge the freezing and confirmation order.

Analysis: The agreements to sell relied upon by Mahavir Singh Saini did not culminate in any registered conveyance, and the record did not show complete payment or completion of transfer. The documents also failed to establish how Plot Nos. 47 and 48 were carved out from the alleged Khasra number or how valid title moved from the stated predecessors to his vendors. In the absence of a completed transfer and a reliable title chain, his claim to ownership could not prevail.

Conclusion: The issue is answered against Mahavir Singh Saini. His appeal was rejected and the freezing confirmation was not disturbed for the properties claimed by him.

Final Conclusion: The impugned order was modified to the extent that Plot No. 47 claimed by Urmil Gupta was excluded from the PMLA restraint, while the challenge raised by Mahavir Singh Saini failed for want of a valid title.

Ratio Decidendi: In proceedings concerning attachment or freezing under PMLA, a claimant must establish a credible and complete chain of title to displace the restraint, and a mere agreement to sell or a doubtful conveyance unsupported by title documents does not suffice.

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