1. This appeal has been filed under section 26 of the Prevention of Money Laundering Act, 2002 (Act of 2002) to challenge an interim order passed
by Adjudicating Authority on 29.09.2023. By the impugned order, four applications preferred by the appellant have been decided.
2. The learned counsel for the appellant submitted that thirteen F.I.Rs were registered in the year 2013 to 2020 by certain allottees of two separate
residential projects undertaken by the company namely M/s IREO Private Limited  and M/s IREO Fire River Private Limited. The appellant was
not named in the FIR. The respondent, Enforcement Directorate recorded ECIR on 15.06.2021 in reference to those 13 FIRs, where also appellant
was not named as an accused.
3. The prosecution complaint was also filed. The appellant was not shown to be an accused therein. However, in pursuance to the authorization under
section 17 (1) of the Prevention Of Money Laundering Act, 2002, herein called Act officers of the Enforcement Directorate conducted search at
several places. They seized several documents, records and the property of the appellant without verifying the source of acquisition of properties. The
appellant accordingly filed a Criminal Writ Petition bearing no. 1751 of 2023 before Delhi High Court against the search operation and consequent
seizure/ freezing of the properties. The said writ petition is still pending before the Delhi High Court.
4. The respondent ED filed an OA before the Adjudicating Authority to seek retention of records and properties seized from various premises and in
pursuance to it, the Adjudicating Authority issued a show cause notice under section 8 (1) of the Act, 2002.
5. The respondent department in the meanwhile filed a supplementary prosecution complaint on 04.08.2023 naming the appellant as an accused for
commission of the offence.
6. The appellant filed preliminary reply to the show cause notice. The appellant thereupon filed an application to seek inspection of records and liberty
to file the reply. It was in reference to Regulation 16, 17 and 18 of the Adjudicating Authority (Procedure) Regulation, 2013. The appellant filed
another application to seek cross examination of the witnesses. The third application was to seek a copy of the reasons to believe recorded in writing
under section 17 and also under section 8 (1) of the Act of 2002. The fourth application was to challenge the constitution of Adjudicating Authority
and accordingly to stay the proceedings till the authority is constituted as per the provisions of law. The Adjudicating Authority dismissed all the
applications by the impugned order dated 29.09.2023.
7. The learned counsel for the appellant has questioned the impugned order by maintaining four different appeals in reference to each application and
accordingly we are deciding each appeal by this common order.
Appeal Number 6686/23 to Challenge the Order Dated 29.09.2023 To Deny Extension of Time For Filing Reply after Inspection Of
Record
8. The learned counsel for the appellant submitted that while inspection of records was permitted by the Adjudicating Authority as per regulation 16 to
18 of the Regulation Act of 2013, the time was not extended for filing the reply.
9. In view of the above, the impugned order needs to be Interfered and accordingly appellant should be allowed to file reply to the show cause after
inspection of record.
10. We have considered the submission of the learned counsel for the appellant and find that a prayer for inspection of record was pressed after filing
reply. The Adjudicating Authority granted permission to apply for the inspection of record in „Form 7‟ and to inspect the record as per Regulation
16 to 18 of the Regulation of 2013. The extension of time for filing of reply was not allowed as the reply to show cause notice was already filed. We
do not find any error in the order of the Adjudicating Authority.
11. If the record was required to be inspected before filing reply, prayer for it should have been made at the earliest so that a reply is filed after
inspection of record. However, in the instant case, the reply to the show cause notice was filed by the appellant and it is only thereafter that he sought
inspection of record with extension of time to file reply. The inspection was permitted but there was no question of extension of time for filing reply
when reply had already been filed. It is to be noted that the proceedings before the Adjudicating Authority has to be completed within 180 days of the
issuance of provisional attachment order and that too after serving a Show Cause Notice, after recording of reasons to believe, as envisaged under
section 8 (1) of the Act of 2002.
12. The notice therein has to be of not less than 30 days on the person calling upon him to indicate the source of his income, earning or assets, out of
which or by means of which he acquired the property. The persons receiving notice is at liberty to file the reply, followed by rejoinder by the
department, if any. It is thereupon the matter is to be taken up for final hearing and thereupon final order is to be passed within 180 days.
13. The proceedings by the Adjudicating Authority has to be completed within time frame and at times, there may be effort of the person receiving
show cause notice to delay the proceedings so that the attachment may lapse with the expiry of 180 days. The person may even seek additional time
to file the reply.
14. In the instant case, 180 days are going to expire on 30.11.2023 as informed to us. Hence, the Adjudicating Authority is required to pass the order
within time frame and accordingly to regulate its schedule and thereby, once the reply to the show cause notice had been filed, there was no reason to
extend the period for filing reply thereupon.
15. Thus, first issue raised by the appellant is decided against them and accordingly the order of the Adjudicating Authority is confirmed on the issue.
The appeal No 6685/23 is to seek stay of the proceedings till Adjudication Authority is constituted with required coram.
16. The second issue raised by the appellant is against the coram of the Adjudicating Authority. The learned counsel for the appellant submitted that
presently there is one Member in the Adjudicating Authority whereas as per section 6 of the Act 2002, it should consist of Chairman and two other
Members and out of it, one member should be having experience in the field of law. At present, only one Member is acting as Adjudicating Authority,
thus it is lacking in coram.
17. Section 6 (3) provides for the qualification for appointment of the Member and one of the qualification is that the Member should be a District
Judge, or a person from the field of law, or a Member of Indian Legal Service. The qualification given in the Regulation is that a Member may also
come from the field of Finance, Accountancy, Administration etc. The constitution of the Adjudicating Authority is suffering from “coram non
judice†as only Member exist and passed the order without proper constitution of the Authority.
18. The learned counsel submits that while the learned Adjudicating Authority relied on the Judgement of Delhi High Court in the case of J Sekar
Versus Union of India & Another in W.P. (C ) 5320/2017 dated 11.01.2018, but failed to rely on the same judgement on the other issue. Thus, one
and the same judgement was relied by the Adjudicating Authority on one issue while denying its application on the other issue.
19. We have considered the submission made by the learned counsel for the appellant and find that the issue raised by the appellant has already been
settled by Delhi High Court in the case of Gold Craft Properties Pvt. Ltd. V/s Directorate of Enforcement 2023 DHC 6887 DB.
20. The Division Bench of the High Court found that even one Member of the Adjudicating Authority is competent to pass the order.
21. The Delhi High Court in the case of Aprajita Kumari and Another Vs. Joint Director, Enforcement Directorate and Another in WP (C )
3008/2016 decided the same issue. It was even in the case of K. Rethinam Versus Union of India and Ors. in WP No. 8115/2017. It was held that
Single Member can pass an order and it is not necessary that said member should be from the Judicial side. It can be an Administrative Member as
well.
22. The same view was taken by Karnataka High Court in the case of Dyani Antony Paul V/s Union of India WP No. 38642/2016 date 11.12.2020 .
23. In view of the above, we do not find any illegality in the impugned order to deny stay of the proceedings till the Adjudicating Authority is constitute
with the coram. In fact, one member of the Adjudicating Authority constitute the corum of the Authority.
The appeal no. 6684/23. The application was filed to seek cross examination of the persons.
24. The appellant made an application to seek permission to cross examine Shri Saket Singh, Deputy Director of ED and two other officials of ED Sh.
K.P. Prajapati and Sumit Upadhyay. The appellant further sought permission to cross examine four Panchas namely Sh. Sahidul Sheikh, Sh. Manas
Patra, Sh. Hakim Singh and Sh. Ravinder Singh.
25. The detail questions to cross examination of the seven persons have been given which are as under:-
A.In respect of Sh. Saket Singh, Deputy Director ED.
1. That the retention of the digital devices, document/ records seized has been done on the basis of presumptions and assumptions, without there being
any nexus with the alleged Scheduled offence,
2. The seizure was done without any analysis and without any purpose of the same with the investigation in the ECIR.
3. He did not even record the evidence/statement of any person before the search and seizure was made. Hence, cross examination of Mr. Saket
Singh, the Original Applicant is required to be done in for a fair adjudication in the present case.
4. It has been stated that the devices, documents, records, etc. has been retained by invoking Section 17 PMLA without proper investigation and
rather only proforma words in the statute are reproduced in the retention order. However, it is the case of the Applicant that the pre-requisites of the
said provision have not been satisfied in the present case and thus in order to prove that the requirements for invocation of Section 17 PMLA, were
not satisfied, Ld. Deputy Director is required to be cross examined on, inter alia, the following aspects:
4.1 On what material he came to the opinion that the records/properties seized are attributed to proceeds of crime, since the same has not been
specified in the Original Application?
4.2 How the Ld. Deputy Director reached the conclusion that the alleged offence of Money Laundering has been committed in the present case when
not even a single witness has been examined?
4.3 Admittedly as stated in para 6 of the OA, scrutiny of the seized documents/records (including digital records) is under process which shall take
time to complete and that the relevance of the documents seized has to be checked and decided. Then on what basis, the Ld. Deputy Director came
to the conclusion for retention of the seized documents/records (including digital records)?
4.4 How the Ld. Deputy Director reached the conclusion that there exists a prima facie case showing connivance and involvement of the Applicants/
Respondent No. 1 & 2 and other Respondents with IREO group and Lalit Goyal for Money laundering for diversion of funds as stated in para7 of the
instant OA?
4.4.1 What tangible and credible evidence indicative of involvement of the respondents in any process or activity connected with the ‘proceeds of
crime’ has come on record in terms of para 284 of the judgment titled Vijay Madanlal Choudhary v. Union of India, 2022 SCC Online SC 929?
4.4.2 Why Retention orders and the Authorizations are not attached to the RUDs?
4.4.3 How unconnected transactions were considered to be connected with the alleged proceeds of crime?
B. In respect Sh. K.P. Prajapat, Assistant Director ED.
(a) What was the mandate scope of conduct of search & seizure operations?
(b) Whether he was authorised to call and take the assistance of ForensicTeam?
(c) Whether there was any specified criteria for seizure of documents, records, digital devices, etc. at the said premises or the documents, records,
etc. were seized en-masse without even checking, etc.?
C. In respect of Sh. Sumit Upadhyay, Assistant Director ED.
(a) What was the mandate scope of conduct of search & seizure operations?
(b) Whether there was any specified criteria for seizure of documents, records, digital devices, etc. at the said premises or the documents, records,
etc. were seized en-masse without even checking, etc.?
D. In respect of Shri Sahidul Shaikh, Pancha/ Witness.
a) Whether he knew Sh. Vineet Maheshwari, VP-Legal, who had called himbefore hand in respect of Panchnama dated 01.06.2023?
b) Whether Sh. Vineet Maheshwari, VP-Legal, who had called him at theinstance of some ED official, whom he knew before hand?
c) Whether he knew Mr. Sumit Upadhyay, the ED official who had called him inrespect of Panchnama dated 04.06.2023 beforehand?
d) When and how was he contacted by the above officials?
e) Where was he located, when he was contacted by the above official?
f) As per the address mentioned in the Panchnama dated 01.06.2023, he is resident of West Bengal and no local address has been mentioned in the
Panchnama. Whether he came all the way from West Bengal?
g) In the Panchnama dated 04.06.2023, address of Gurugram has been mentioned, why different addresses are mentioned in two panchnamas?
h) How much time did it take for him to reach the place of search?
i) Whether he was told the purpose as to why he was being called by the aboveED official?
j) Whether he was aware of his role as Pancha and he understood the process ofsearch or seizure and why it was being done?
k) Whether he was given any sets of instructions by the above ED official whocalled him to witness such search, seizure?
l) Were there any factors that might have influenced his observation during the process as recorded in the Panchnama?
E. In respect of ShriManas Patra, Pancha/ Witness.
a) Whether he knew Sh. Vineet Maheshwari, VP-Legal, who had called himbefore hand in respect of Panchnama dated 01.06.2023?
b) Whether Sh. Vineet Maheshwari, VP-Legal, who had called him at the instanceof some ED official, whom he knew before hand?
c) Whether he knew Mr. Sumit Upadhyay, the ED official who had called him inrespect of Panchnama dated 04.06.2023 beforehand?
d) When and how was he contacted by the above officials?
e) Where was he located, when he was contacted by the above official?
f) As per the address mentioned in the Panchnama dated 01.06.2023, he is resident of West Bengal and no local address has been mentioned in the
Panchnama. Whether he came all the way from West Bengal?
g) In the Panchnama dated 04.06.2023, address of Gurugram has been mentioned, why different addresses are mentioned in two panchnamas?
h) How much time did it take for him to reach the place of search?
i) Whether he was told the purpose as to why he was being called by the aboveED official?
j) Whether he was aware of his role as Pancha and he understood the process ofsearch or seizure and why it was being done?
k) Whether he was given any sets of instructions by the above ED official whocalled him to witness such search, seizure?
l) Were there any factors that might have influenced his observation during theprocess as recorded in the Panchnama?
F. In respect of Shri Hakim Singh, Pancha/ Witness.
a) Which ED official called him and whether he knew the said ED official beforehand?
b) When and how was he contacted by the above ED official?
c) Where was he located, when he was contacted by the above ED official?
d) How much time did it take for him to reach the place of search?
e) Whether he was told the purpose as to why he was being called by the above ED official?
f) Whether he was aware of his role as Pancha and he understood the process of search or seizure and why it was being done?
g) Whether he was given any sets of instructions by the above ED official who called him to witness such search, seizure?
h) Were there any factors that might have influenced his observation during the process as recorded in the Panchnama?
i) Whether the Panchnama was written at the spot in his presence? Whether he signed the Panchnama voluntarily after reading and understanding the
contents of the Panchnama or he was forced to sign the Panchnama?
G. In respect of Shri Ravinder Singh, Pancha/ Witness.
a) Which ED official called him and whether he knew the said ED official beforehand?
b) When and how was he contacted by the above ED official?
c) Where was he located, when he was contacted by the above ED official?
d) How much time did it take for him to reach the place of search?
e) Whether he was told the purpose as to why he was being called by the above ED official?
f) Whether he was aware of his role as Pancha and he understood the process of search or seizure and why it was being done?
g) Whether he was given any sets of instructions by the above ED official who called him to witness such search, seizure?
h) Were there any factors that might have influenced his observation during the process as recorded in the Panchnama?
i) Whether the Panchnama was written at the spot in his presence? Whether he signed the Panchnama voluntarily after reading and understanding the
contents of the Panchnama or he was forced to sign the Panchnama?
26. The appellant have framed the issues for cross examination, however, prayer for cross examination of persons named in the application was not
accepted by the Adjudicating Authority and therefore the impugned order has been challenged even in reference to it.
27. The prayer to seek cross examination of the Officers and Panchas has been seriously contested by the respondents and accordingly we would
deal with the issue after considering the rival submissions.
28. Before we address the issue, it would be relevant to refer that proceedings under section 8 of the Act of 2002 are summary in nature. Once the
order of provisional attachment of the properties is issued by the Enforcement Directorate, copy of it is to be sent to the Adjudicating Authority for
passing order within 180 days from the date of the order of provisional attachment.
29. The Adjudicating Authority, before proceeding further in reference to the provisional attachment order, is to draw a show cause notice. It should
contain reasons to believe and thereupon to be served to the person whose properties have been attached. It is to seek his reply and the period for it
has been given under the Regulation. Thus, the proceedings by the Adjudicating Authority is to be completed within time-frame and for ready
reference, Section 5 of the Act of 2002 is quoted here under:-
Section 5 in The Prevention of Money-Laundering Act, 2002
5 Attachment of property involved in money-laundering. â€
(1) Where the Director, or any other officer not below the rank of Deputy Director authorised by him for the purposes of this section, has reason to
believe (the reason for such belief to be recorded in writing), on the basis of material in his possession, thatâ€
(a) any person is in possession of any proceeds of crime;
(b) such person has been charged of having committed a scheduled offence; and
(c) such proceeds of crime are likely to be concealed, transferred or dealt with in any manner which may result in frustrating any proceedings relating
to confiscation of such proceeds of crime under this Chapter, he may, by order in writing, provisionally attach such property for a period not exceeding
9 [one hundred and fifty days] from the date of the order, in the manner provided in the Second Schedule to the Income-tax Act, 1961 (43 of 1961)
and the Director or the other officer so authorised by him, as the case may be, shall be deemed to be an officer under sub-rule (e) of rule 1 of that
Schedule:
10 [Provided that no such order of attachment shall be made unless, in relation to the scheduled offence, a report has been forwarded to a Magistrate
under section 173 of the Code of Criminal Procedure, 1973 (2 of 1974), or a complaint has been filed by a person, authorised to investigate the offence
mentioned in the Schedule, before a Magistrate or court for taking cognizance of the scheduled offence, as the case may be: Provided further that,
notwithstanding anything contained in clause (b), any property of any person may be attached under this section if the Director or any other officer not
below the rank of Deputy Director authorised by him for the purposes of this section has reason to believe (the reasons for such belief to be recorded
in writing), on the basis of material in his possession, that if such property involved in money-laundering is not attached immediately under this Chapter,
the non-attachment of the property is likely to frustrate any proceeding under this Act.]
(2) The Director, or any other officer not below the rank of Deputy Director, shall, immediately after attachment under sub-section (1), forward a
copy of the order, along with the material in his possession, referred to in that sub-section, to the Adjudicating Authority, in a sealed envelope, in the
manner as may be prescribed and such Adjudicating Authority shall keep such order and material for such period as may be prescribed.
(3) Every order of attachment made under sub-section (1) shall cease to have effect after the expiry of the period specified in that sub-section or on
the date of an order made under sub-section (2) of section 8, whichever is earlier.
(4) Nothing in this section shall prevent the person interested in the enjoyment of the immovable property attached under sub-section (1) from such
enjoyment. Explanation.â€" For the purposes of this sub-section “person interestedâ€, in relation to any immovable property, includes all persons
claiming or entitled to claim any interest in the property.
(5) The Director or any other officer who provisionally attaches any property under sub-section (1) shall, within a period of thirty days from such
attachment, file a complaint stating the facts of such attachment before the Adjudicating Authority.
(i) Paragraph 1 of Part A and Part B of the Schedule, a report has been forwarded to a Magistrate under section 173 of the Code of Criminal
Procedure, 1973 (2 of 1974); or (ii) Paragraph 2 of Part A of the Schedule, a police report or a complaint has been filed for taking cognizance of an
offence by the Special Court constituted under sub-section (1) of section 36 of the Narcotic Drugs and Psychotropic Substances Act, 1985 (61 of
1985).â€.
30. Section 5 (1) reveals that order of provisional attachment would be for a period not exceeding 180 days and therefore the confirmation of the order
under section 8 of the PML Act of 2002 has to be made within a period of 180 days.
31. Keeping in mind Authority determine the the time frame, the Adjudicating schedule for disposal of the case and for which initially opportunity to
file reply within 30 days from the date of show cause notice is given. If the additional time is sought and granted, then period may be greater than 30
days for filing reply. The Department then file rejoinder, if so wishes and the entire process takes considerable time and therefore matter is to be kept
immediately for final hearing so that order may be passed within 180 days of the date of provisional attachment order. The fact aforesaid is relevant
for determination of the issue raised by the appellant to seek cross examination of the persons.
32. The cross examination is generally sought at the stage leaving hardly any time for the Adjudicating Authority to pass the final order. It is aimed to
seek lapse of the attachment. It is however a fact that cross examination is a part of principle of natural justice. Thus in a given case, it should be
allowed and for that purpose, we may refer the facts of case.
33. It is a case where appellants made an application to seek cross examination of seven persons. It is without their statement either during the course
of investigation or otherwise because cross-examination pre-supposes statement of the persons sought to be cross examined. It is a fact that no
statement of any of the persons named by the appellant were recorded. In absence of statement, there would be no question of cross examination of
the witness as cross examination pre-supposes examination in Chief of the witness. Thus, application for the cross examination was made only to gain
time so that attachment order may lapse. The cross examination is permitted in quasi judicial proceedings, but when the testimony of the witness is
relied by the parties.
34. In view of the above, when statement of witness sought to be cross examined does not exist, question of cross examination would not arise. The
issue of principle of natural justice in reference to cross examination was decided by the Apex Court in the case of Kanungo & Company V/s
Collector of Customs & Others reported in 1972 SC 2136 Para 12 of judgement is quoted here under:-
12. We may first deal with the question of breach of natural justice. On the material on record, in our opinion, there has been no such
breach. In the show-cause notice issued on August 21, 1961, all the material on which the Customs Authorities have relied was set out and it
was then for the appellant to give a suitable explanation. The complaint of the appellant now is that all the persons from whom enquiries
were alleged to have been made by the authorities should have been produced to enable it to cross-examine them. In our-opinion, the
principles of natural justice do not require that in matters like this the persons who have given information should be examined in the
presence of the appellant or should be allowed lo be cross-examined by them on the statements made before the Customs Authorities.
Accordingly we hold that there is no force in the third contention of the appellant.
35. The judgement of the Apex Court in Kanungo & Company (Supra) was relied by the Apex Court in the case of Telestar Travels Private Ltd V/s
Enforcement Directorate 2013 9 SCC 549. Delhi High Court also addressed the same issue in the case of Arun Kumar Mishra Vs Union of India and
Another LPA/99/2014 in following words:-
“11.We have further enquired from the senior counsel for the appellant that even if the appellants are right in their contention of having
a right to cross-examine the persons whose oral testimony is intended to be used against the appellants and even if the Adjudicating
Authority is wrongly depriving the appellants of the said right, is it not open to the appellants to, if at all aggrieved by the orders of the
Adjudicating Authority, to take up the said aspect in appeal under Section 26 of the Act against the said orders and which right of the
appellants has been protected in the impugned order by the learned Single Judge also.
12. The senior counsel for the appellant, though not controverting the aforesaid legal position, contends that if the appellants have a right
in law to cross-examine the witnesses whose testimonies are intended to be used against the appellants, why should this Court not interfere
at this stage itself instead of allowing the Adjudicating Authority to proceed on a futile exercise and which will only result in multiplicity of
proceedings.
13. We are unable to agree. The Adjudicating Authority is currently seized of the complaints. We, at this stage, do not know as to which way
the order of the Adjudicating Authority will go. It cannot also be said at this stage whether the Adjudicating Authority even if deciding
against the appellants will rely upon the material before it qua which the appellants claim a right of cross-examination. All this can be
known only when the Adjudicating Authority passes an order and qua which if the appellants are aggrieved, the appellants shall have their
statutory remedy.
Any interference by us at this stage in the proceedings of which the Adjudicating Authority is seized is thus uncalled for and would result in
a situation which the Supreme Court has warned the High Courts to avoid.â€
36. We have been informed now that the Adjudicating Authority has already passed the final order on 8th November, 2023 and a copy of it has been
supplied to the Tribunal. The order was passed before giving written arguments by the appellant for which liberty was sought and granted by the
Tribunal. The written arguments were given on 10th November, 2023. In any case, we do not find that denial of opportunity of cross examination has
caused any prejudice to the appellant. It is for the reason that statements of the persons sought to be cross examined were not recorded so as to rely
their testimony.
37. It is apart from the fact that the Regulation does not provide for cross examination of a person whose statement or the testimony was not recorded
at any time and specifically during the course of investigation. The appellant has cited many judgements on the principle of natural justice and we
agree with the proposition of Law, but cross examination in summary proceedings cannot be claimed as rule.
38. In the light of the aforesaid, there was no reason to allow cross examination of the persons who can otherwise be cross examined by the appellant
in the Criminal Trial, if prosecution produced them as witness and their statement are recorded in the Court. For all the reasons given above, we do
not find any illegality in the order of the Adjudicating Authority to deny cross examination of the persons named by the appellant.
39. The appeal No. 6683/23. For supply of the copy of reasons to believe
The last issue raised by the appellant is in reference to denial to serve a copy of reasons to believe recorded under section 17 of the Act of 2002. It is
otherwise a fact that the appellant was served with a copy of reasons to believe while issuing show cause notice by the Adjudicating Authority. It is
otherwise envisaged under section 8 (1) of the Act of 2002. The appellant was given reasons to believe while recorded by the Adjudicating Authority
what has been prayed is the copy of reasons to believe recorded at the time of search under section 17 of the Act of 2002 and thereby the appellant
has asked for two sets of reasons to believe, one recorded while issuing show cause notice under section 8 (1) of the Act of 2002 and another under
section 17 of the Act.
40. It was informed to us that final order has been passed by the Adjudicating Authority before giving written arguments of this by the appellant. Thus,
it would be appropriate to keep this issue open for the appellant and to be taken up while filing appeal against the final order of the Adjudicating
Authority, if they so choose.
41. The liberty aforesaid has been given keeping in mind that the issue is pending consideration before the Apex Court and if it is held that copy of
reasons to believe recorded under section 17 is to be supplied then appropriate order would be passed in conformity of the order of the Apex Court
while hearing the appeal. However, if the pending appeal before the Apex Court in the case of J. Sekar is decided adverse to the appellant holding
that there is no necessity to supply a copy of reasons to believe recorded under section 17 which is otherwise to be kept in sealed envelope, the matter
would be decided accordingly.
42. Thus, last issue is kept open for the appellant and if he so wishes, can take it in the appeal against the final order, as otherwise, Interim Orders
merges in the Final Order.
With the aforesaid, all the appeals are disposed off.
