Delhi High Court orders release of M3M’s seized assets and title deeds after ED provisionally attaches ₹404 crore

The petition was filed under Article 226 of the Constitution and Section 482 of the Code of Criminal Procedure, 1973 (“CrPC”).

The petitioners stated that the challenge concerning summons for personal appearance had become infructuous.

During the proceedings, the Directorate of Enforcement (“ED”) passed a Provisional Attachment Order dated 17 July 2026, attaching land parcels valued at ₹404 crore.

The ED had earlier seized assets during a search under Section 17 of the Prevention of Money Laundering Act, 2002 (“PMLA”); it stated that the seized cash, jewellery, vehicles and fixed deposits were no longer part of the investigation.

The petitioners also submitted that the land parcels covered by the attachment order were distinct from the land whose title deeds they had deposited pursuant to an order dated 12 June 2023.

Whether the petitioners’ challenge concerning the summons for personal appearance remained live.

Whether the assets seized by the ED and identified in Tables 1–4 should be released, and whether the title deeds deposited pursuant to the Court’s earlier order should be returned in light of the subsequent attachment of ₹404 crore in other properties.

The petition invoked Article 226 of the Constitution and Section 482 CrPC, while the ED’s search was conducted under Section 17 of the PMLA.

The Court did not set out or apply a substantive statutory test or precedent governing provisional attachment or release of seized assets.

Its directions were based on the case-specific circumstances recorded in the order, including the ED’s statements about the seized assets and the subsequent attachment; the Court expressly declined to express any view on the merits of that attachment or the pending proceedings.

The summons-related prayer had become infructuous because the date fixed for appearance had passed.

As to the seized assets, the ED stated that the cash, jewellery, vehicles and fixed deposits were no longer part of the investigation, and the Court directed release of the assets listed in Tables 1–4.

The Court also noted that the ED had provisionally attached other properties valued at ₹404 crore.

Since the title deeds deposited under the Court’s earlier order related to land outside that attachment, the Court directed their return.

It made clear that these directions did not determine the merits of the attachment or the pending proceedings.

The Court directed the ED to release forthwith the assets detailed in Tables 1–4 to the petitioners or their authorised representatives.

It also directed the return of the deposited title deeds, clarifying that the land concerned was not covered by the ED’s 17 July 2026 Provisional Attachment Order.

The petition and pending applications were disposed of, without any expression on the merits of the attachment or the proceedings against the M3M Group of Companies.