Uttarakhand High Court has ruled that searches under Section 17 of the PMLA after filing of prosecution complaint do not amount to 'evergreening' of investigation, affirming validity of post-filing evidence collection.
Uttarakhand HC Upholds Post-Complaint PMLA Searches
The Uttarakhand High Court has held that conducting searches under Section 17 of the Prevention of Money Laundering Act (PMLA), 2002, after the filing of a prosecution complaint does not constitute ‘evergreening’ of investigation. The Court ruled such actions permissible under Section 44 of the PMLA, which allows further investigation post-complaint.
The Court clarified that the investigation agency may gather additional evidence after filing the charge sheet, provided it pertains to the same predicate offence or connected laundering activities. The ruling emphasized procedural continuity rather than procedural abuse.
This decision supports investigative flexibility in complex financial crime cases and reinforces agencies’ powers to secure supplementary evidence. Defence counsel must now anticipate post-filing searches and prepare to challenge their relevance or proportionality during trial.
Citations
- Section 17, PMLA
- Section 44, PMLA

