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The High Court held that forceful possession of property can be considered proceeds of crime u/s 2(1)(u) of PMLA. Money laundering involves any activity connected with proceeds of crime derived from criminal activity. Illegal possession of property falls within the definition of property u/s 2(1)(v) of PMLA. Even attempts to conceal, possess, or use proceeds of crime constitute money laundering. The court upheld the validity of section 19 of PMLA. The ED's case against the petitioner is supported by evidence, and the legality of subsequent remand orders does not affect the initial arrest. The petitioner's petition was dismissed.