Broad definition of "deposit" under MPID Act encompasses loan transactions, irrespective of nomenclature or civil nature.

The appellants, a family and two companies, invested Rs. 2.51 crore with Respondent Nos. 2 to 6 between 2016 and 2019 for a resort project, based on promises of 24% annual interest

When the respondents defaulted on both interest and principal, the appellants initiated various legal actions, including summary suits and a Section 138 NI Act notice

Previous attempts to register an FIR under the IPC were rejected by the High Court, which termed the transaction a "loan" of a civil nature

Subsequently, the appellants sought to register an FIR under Section 3 of the MPID Act. The Sessions Court and the High Court dismissed the application, holding that a "loan transaction" does not constitute a "deposit" under the MPID Act and that the respondents were not a "financial establishment"

1. Whether the amounts advanced by the appellants fall within the definition of "deposit" under Section 2(c) of the MPID Act

2. Whether the respondents fall within the definition of "financial establishment" under Section 2(d) of the MPID Act

3. Whether the failure to establish offences under the IPC operates as a bar to invoking the provisions of the MPID Act

Section 2(c) of the MPID Act, which defines "deposit" broadly as "any receipt of money" to be returned with or without benefit

Section 2(d), which defines "financial establishment" as "any person" accepting such deposits

the precedent State of Maharashtra v. 63 Moons Technologies Ltd. (2022), which established that the use of "any" and "includes" in these definitions reflects a legislative intent to cast a "broad and comprehensive" net, creating a legal fiction that is inclusive rather than restrictive

Section 3 of the MPID Act regarding "fraudulent default"

The Court reasoned that the transaction fulfilled all three essential ingredients of a "deposit" under Section 2(c): (i) receipt of money, (ii) obligation to return after a specified period, and (iii) return with interest

It rejected the High Court's view that the transaction was merely a "loan," stating that nomenclature is irrelevant; as long as the attributes of a deposit are met, it falls under the Act

because Section 2(d) defines a "financial establishment" as "any person" (with specific exclusions like banks), the private respondents were covered

the MPID Act is a self-contained, independent statutory regime. Therefore, the inability to prove IPC offences like cheating or criminal breach of trust does not preclude a complaint under Section 3 of the MPID Act, as the two operate in distinct legal spheres

The Supreme Court allowed the appeal and set aside the High Court's judgment. The Court concluded that the appellants are entitled to invoke Section 3 and proceed with their remedies under the MPID Act, regardless of the outcome of previous IPC-related proceedings. The High Court’s imposition of costs was also effectively set aside.