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of Proceeds of crime include illegal gratification obtained through corrupt activities, even before the amendment to Section 3 of the Prevention of Money Laundering Act (PMLA). The definition of 'proceeds of crime' u/s 2(1)(u) PMLA covers involvement in corrupt practices. The Supreme Court's decision in Vijay Madanlal Chaudhary's case clarified that mere possession of proceeds of crime is not required for invoking PMLA provisions. The trial court correctly considered the pre-amended Section 3 and the Supreme Court's interpretation. Therefore, the High Court rejected the petitioner's contention regarding retrospective application and confirmed the trial court's order.
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