Unexplained cash deposits and unrebutted presumption under PMLA sustained attachment over assets linked to money laundering.

Unexplained cash deposits in bank accounts, made in multiple tranches over a short period and inconsistent with known income, were held sufficient to sustain attachment under the Prevention of Money Laundering Act, 2002. The explanation based on marriage gifts, family deposits, savings, medical funds, and demonetisation-related cash was found uncorroborated and internally inconsistent. On those facts, the statutory presumption under Section 24 remained unrebutted, so the finding that the attached assets were involved in money laundering was upheld and the attachment confirmed.

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Issues: Whether the provisional attachment confirmed under the Prevention of Money Laundering Act, 2002 could be sustained on the basis of the appellant's cash deposits and whether the appellant had rebutted the statutory presumption by a credible and corroborated explanation.

Analysis: The cash deposits in the appellant's bank accounts were substantial, occurred in multiple tranches over a short period, and were not satisfactorily explained by the marriage-gift theory or other asserted sources. The explanations regarding deposits by family members, cash savings, medical funds, and demonetisation-related deposits were found inconsistent, uncorroborated, or unsupported by reliable evidence. The materials on record showed that the deposits did not match the appellant's known income and earning capacity. In these circumstances, the statutory presumption under Section 24 remained unrebutted, and the finding that the attached assets were involved in money laundering was upheld.

Conclusion: The attachment was sustained and the challenge to the impugned order failed.

Final Conclusion: The appeal was dismissed and the confirmation of attachment under the money-laundering was left undisturbed.

Ratio Decidendi: Where the recorded transactions and surrounding circumstances show unexplained cash deposits inconsistent with known sources of income, and the explanation offered is not corroborated by reliable evidence, the statutory presumption against the holder of the assets is not rebutted and the attachment may be sustained.

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