The Supreme Court, in M3M v. Directorate of Enforcement, permitted substitution of immovable property attached under the PMLA with alternate immovable assets of equal or higher value. A Bench of Justices P.S. Narasimha and R. Mahadevan allowed the real estate firm’s request to replace provisionally attached land with commercial units in its Gurugram project, valued at ₹317 crore, as confirmed by the ED. The Court imposed conditions outlined in the ED’s affidavit and disposed of the SLP. This ruling, building on Revati Cements v. UOI, expands the principle of substitution from fixed deposits to immovable property, balancing enforcement under PMLA with the need to ensure continuity of commercial projects.
