The Karnataka High Court at Bengaluru has dismissed two writ petitions filed by JSW Steel Limited challenging proceedings concerning attachment of its bank accounts under the Prevention of Money Laundering Act, 2002 (PMLA). The Division Bench held that the company had been given an effective opportunity to present its case before the authorities and that the pending appellate proceedings could not be bypassed.
The judgment was delivered on September 30, 2026, by Justice D K Singh and Justice T.M. Nadaf.
Background
The proceedings arose from a CBI case registered in 2011 concerning alleged irregularities connected with iron ore mining and transportation. The Enforcement Directorate (ED) subsequently registered proceedings under the PMLA, treating the alleged proceeds arising from the underlying scheduled offences as “proceeds of crime.”
During the investigation, the ED examined transactions involving JSW Steel. The authorities alleged that iron ore had been supplied to the company by Associated Mining Company and that certain amounts remained payable in connection with those transactions. A provisional attachment order was subsequently issued concerning bank accounts of JSW Steel.
The Adjudicating Authority confirmed the attachment order in April 2021. JSW Steel then approached the PMLA Appellate Tribunal, arguing, among other things, that its written submissions and synopsis had not been properly considered.
The High Court rejected the argument that failure to specifically refer to every written submission amounted to denial of natural justice.
The Bench explained that natural justice requires a meaningful opportunity to know the case and present a defence, but it does not require an authority to reproduce or separately answer every submission made by a party.
"The principle of natural justice does not invariably require a separate right to file synopsis or written submissions/arguments nor does it require the Court/Authority to reproduce or expressly deal with every submission. The essential requirement is that the affected person must receive a real and effective opportunity to know the case against him and to present the defence in a manner appropriate to the statutory scheme and circumstances."
The Court noted that JSW Steel had filed its reply to the show-cause notice and had been represented through counsel. It further observed that the Appellate Tribunal had allowed the company to raise all issues relating to facts and law while the appeals remained pending.
The Bench also referred to the Supreme Court’s earlier decision in the same matter, which had emphasised that the statutory appellate process under the PMLA should ordinarily be allowed to proceed.
The Karnataka High Court held that the writ petitions were not maintainable because the statutory appeals before the PMLA Appellate Tribunal were still pending and no prejudice had been established against JSW Steel.
The Court accordingly dismissed Writ Petition Nos. 9583 of 2025 and 8943 of 2025 without costs.
Pending applications, if any, were also disposed of.
