ED Restores ₹520.80 Crore to Successful Resolution Applicant in Cox & Kings Money Laundering Case.

Headnote:

The Enforcement Directorate (ED), Mumbai Zonal Office secured the restoration of ₹520.80 crore—representing the substituted value of attached properties—to Macrotech Developers Ltd., the Successful Resolution Applicant (SRA) in the insolvency proceedings of V Hotels Ltd. The Supreme Court, acknowledging the ED’s stance under Section 8(8) of the PMLA and Section 32A of the IBC, ordered restitution of the fixed-deposit amount (with interest) to the SRA, subject to verification that it had no links with the original management involved in laundering proceeds of crime. The Court also placed on record appreciation of the ED officers' efforts in ensuring fair restoration while protecting public interest.

Background:

• The ED investigated Cox & Kings Ltd. (CKL), its promoters and others for large-scale financial fraud involving Proceeds of Crime amounting to approximately ₹4,100 crore.

• During the investigation, the ED traced ₹1,066 crore of the laundered funds to M/s V Hotels Ltd.

• Out of this, ₹520.80 crore remained outstanding, and properties equivalent to this value were attached under the PMLA, with the attachment subsequently confirmed by the Hon’ble Adjudicating Authority.

• V Hotels Ltd. later entered Corporate Insolvency Resolution Process (CIRP) under the IBC.

• Macrotech Developers Ltd. was approved as the Successful Resolution Applicant (SRA).

Court Proceedings & Developments

• In compliance with an order of the Hon’ble Supreme Court (passed in the SLP filed by the ED), the SRA deposited ₹520.80 crore in an interest-bearing fixed deposit with SBI, representing the substituted value of the attached assets.

• During Supreme Court proceedings, the ED submitted that, in line with:

– Section 8(8) of the PMLA, which enables restoration of confiscated or attached assets to legitimate claimants, and

– Section 32A of the IBC, which grants protection to bona fide resolution applicants,

restitution may be permitted, provided the SRA had no connection with the previous management or beneficiaries of the Proceeds of Crime.

• This position was consistent with the ED’s approach in previous similar matters.

Supreme Court’s Observations:

• The Supreme Court ordered restoration of the ₹520.80 crore deposit, along with accumulated interest, in favour of the SRA under Section 8(8) of the PMLA.

• The Court recorded explicit appreciation for the Directorate of Enforcement, noting:

“We place on record our appreciation for the earnest efforts made by the officers of the Directorate of Enforcement in restoring the attached properties to secure the interests of justice.”

• The Court’s decision affirmed the statutory harmony between PMLA and IBC, ensuring that legitimate stakeholders are protected while still enabling prosecution of money-laundering offences.

Legal Provisions Discussed:

• Section 8(8), Prevention of Money Laundering Act, 2002 (PMLA) – Restoration of confiscated/attached property to rightful claimants.

• Section 32A, Insolvency and Bankruptcy Code, 2016 – Protection to successful resolution applicants from prior offences of the corporate debtor.

• IBC CIRP Framework – Resolution process involving substitution of attached assets with monetary equivalent.

Citation: Press Release, Directorate of Enforcement, 28 November 2025

Case: Enforcement Directorate (Mumbai Zonal Office) – Cox & Kings Ltd. Money Laundering Investigation

Authority: Directorate of Enforcement & Supreme Court of India

Date of Order: As per Supreme Court direction (referenced in SLP filed by ED)

Statutes Involved: PMLA, 2002 & Insolvency and Bankruptcy Code, 2016