top of page

The Paradox Of Economic Sovereignty: A Jurisprudential Analysis Of Double Jeopardy And Procedural Fairness Within The PMLA Framework




Pradeep Kumar, Chanakya National Law University, Patna

Rupesh Kumar, Chanakya National Law University, Patna


ABSTRACT


The constitutional protection against double jeopardy, enshrined in Article 20(2) of the Indian Constitution, serves as a vital safeguard against repetitive state prosecution. However, the rise of the Prevention of Money Laundering Act, 2002 (PMLA) has introduced a complex "dual-track" enforcement mechanism that tests the limits of this doctrine. This article examines the intersection of Article 20(2) and the PMLA, analyzing the "standalone" nature of laundering offenses versus their inherent dependency on predicate crimes. By synthesizing the landmark Vijay Madanlal Choudhary (2022) judgment with cutting-edge 2024–2026 rulings from the Supreme Court and High Courts, this research explores the "continuing offense" fiction, the "automatic collapse" principle, and the recent judicial shift toward procedural fairness under Article 21. It concludes that while PMLA prosecutions rarely trigger traditional double jeopardy bars due to the "identity of offense" test, emerging mandates for transparency and the "No Wall, No Plaster" doctrine are providing new avenues for constitutional relief in an era of aggressive financial regulation.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

Submit Manuscript: Click here

Licensing: 

 

All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

Disclaimer:

The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

bottom of page