Bombay High Court Sets Aside ₹100 Crore PMLA Freeze on Coda Payments, Cites Lack of Reasoned Order

Case Title:  M/s Coda Payments India Pvt. Ltd. v. Dy. Director, Directorate of Enforcement

Case No.: Criminal Appeal (ST) No. 13953 of 2025

Coram: Justice A. S. Gadkari and Justice Kamal Khata

Court Observation

“… the Authority merely states that the material shown in the O.A is sufficient to arrive at satisfaction that retention/continuation of the bank accounts and payment aggregator/payment gateways is required for the purpose of adjudication under Section 8 of the P.M.L.A. The Order however does not separately identify the property… found to be involved in money laundering…,”

“If an Adjudicating Authority omits the mandatory finding under Section 8(2), the Appellate Tribunal cannot thereafter supply that finding on the basis of the same material. If that were done then the statutory safeguard contained in Section 8(2) would effectively become optional.”

“Gross business turnover, however, cannot by itself establish that the entirety of the turnover represents ‘proceeds of crime’. The fact that money has moved from India to an overseas group entity may be relevant to an investigation. It does not, without more, establish that every amount in the company’s bank accounts constitute ‘proceeds of crime’,”

“We are also unable to comprehend the basis on which the E.D. has attached a sum total of Rs. 100 crores without establishing that all the transactions made on the Apps were done by minors or were on account of an unauthorized ‘auto-debit’. It is impossible to comprehend that, transaction totaling to Rs 2,854 crores were all done through fraudulent auto-debit and were all unsecured payments.”

Bombay High Court Sets Aside ₹100 Crore PMLA Freeze on Coda Payments, Cites Lack of Reasoned Order