Chhattisgarh High Court Upholds ED Attachment Of Properties Linked To Former IAS Officer In Coal Levy Scam

The Chhattisgarh High Court has recently upheld the attachment of properties worth about Rs.5.52 crore linked to former IAS officer Ranu Sahu and her family members in a money laundering case arising out of the alleged coal levy scam, affirming action taken by the Directorate of Enforcement (ED).

A Division Bench of Chief Justice Ramesh Sinha and Justice Ravindra Kumar Agrawal dismissed a batch of appeals filed by Sahu and her relatives challenging the October 16, 2025 order of the PMLA Appellate Tribunal.

The tribunal had upheld the Adjudicating Authority's October 9, 2023 confirmation order relating to provisional attachment under the Prevention of Money Laundering Act (PMLA).

Upholding the attachment, the High Court said, “The PAO is therefore in consonance with the statutory scheme under PMLA and is liable to be upheld"

It added that “there exists a reasonable belief, duly recorded and supported by material evidence, that the attached properties are involved in money laundering and further, the appellants have failed to rebut the statutory presumption under Section 24 of the PMLA. We do not find that any question of law arises in these appeals to be answered"

The case arises from an FIR registered on July 12, 2022, followed by an ECIR dated September 29, 2022 by the ED. The agency alleged that a coal transportation syndicate led by Suryakant Tiwari collected an illegal levy of Rs. 25 per tonne after a government order dated July 15, 2020 altered the permit system.

According to the ED, Sahu, during her tenure as Collector in coal-rich districts from June 2021 to February 2023, facilitated the alleged illegal levy collections and received proceeds of crime worth Rs 5.52 crore. The agency claims this money was channelled into properties purchased in the names of her family members.

The High Court was not persuaded by the challenge to the attachment. It held that the ED had recorded a valid “reason to believe”, backed by material evidence to attachment. It also noted that the statutory presumption under Section 24 of the PMLA had not been rebutted.

On the scope of attachment, the bench pointed to the scheme of the PMLA, observing that it permits action not only against tainted assets but also against properties representing the value of proceeds of crime.

"Even if certain properties were acquired prior to the posting of the appellant, Ranu Sahu, as Collector, Korba, it cannot be conclusively held that such properties are immune from attachment. The statutory framework governing the field, provides a clear and unambiguous definition of the expression “proceeds of crime” under Section 2(1)(u) of the PMLA. The term encompasses not only property directly or indirectly derived or obtained as a result of criminal activity relating to a scheduled offence, but also extends to the value of such property. Crucially, the legislative intent underlying this definition is expansive. By specifically including within its ambit “the value of any such property,” the statute empowers the authorities, including the ED, to identify and attach properties equivalent in value to the proceeds of crime. This principle operates irrespective of whether such equivalent property was itself acquired through lawful means or prior to the commission of the alleged offence."

Accordingly, finding sufficient material to indicate such nexus in the present case and no infirmity in attachment orders, the court dismissed the appeals and upheld the ED's action.