Interplay Between Acquittal In Predicate Offences And PMLA Prosecutions: Post-Vijay Madanlal Chaudhary Analysis
- IJLLR Journal
- Nov 16, 2025
- 1 min read
Diksha, B.A. LL.B. (Hons), Vivekananda Institute of Professional Studies – Technical Campus, GGSIPU
ABSTRACT
The Prevention of Money Laundering Act, 2002 gives a complicated connection between underlying crimes and prosecutions for money laundering. Subsequently to the Supreme Court's decision in Vijay Madanlal Choudhary, which determined that an individual who has been finally absolved either by discharge, acquittal, or quashing cannot be subjected to PMLA actions, High Courts have produced varying interpretations on whether this principle is absolute or allows for exceptions.
This paper examines whether the post-Vijay Madanlal jurisprudence has successfully resolved the relationship between predicate offence termination and PMLA prosecution continuance, or whether judicial divergence has created an untenable legal position requiring legislative or Supreme Court intervention, through a comparative analysis of recent High Court decisions from 2024-2025. The analysis results are that the Delhi HC and Punjab & Haryana HC strongly support the automatic collapse principle, but the Madras HC has introduced controversial "technical grounds" exceptions which creates judicial divergence and uncertainty.
Keywords: Vijay Madanlal Choudhary, money laundering, PMLA, scheduled offence, acquittal, automatic collapse, predicate offence, final absolution.
