Dismissed¶16

Directorate of Enforcement v. Kanwar Deep Singh and Ors.

Delhi HC27 Nov 2025CRL.M.C./2483/2022

Case brief

AI extract

What is this about?

Directorate of Enforcement; Kanwar Deep Singh; CRL.M.C. 2483/2022; Delhi High Court; Ravinder Dudeja; 27.11.2025; impugned order 22.03.2022; supply of list of unrelied upon documents; documents collected during investigation not forming part of record; inspection of seized material kept open; Sarla Gupta vs. Directorate of Enforcement; 2025 INSC 645; petition dismissed as withdrawn; compliance within six weeks.

What did the court decide?

Petition dismissed as withdrawn; petitioner (Directorate of Enforcement) directed to make compliance of the impugned order within six weeks; inspection issue left open to be decided on a future application. ¶16

Directorate of Enforcement Vs Kanwar Deep Singh and Ors. — Delhi HC (2025) — LawSathi Research

What the court decided

AI extract

Outcome

¶16

Issue for consideration

Whether the Directorate of Enforcement was bound to comply with the trial court's direction to supply a list of material and documents collected during investigation but not relied upon / not forming part of the record. +1 more

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Court's answer

In view of the Special Counsel's statement (taking on record reliance on Sarla Gupta v. Directorate of Enforcement, 2025 INSC 645) that the ED shall abide by the impugned order insofar as it directs supply of the list of unrelied-upon documents, the petition is dismissed as withdrawn, with a direction to the petitioner to comply with the impugned order within six weeks.

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Ratio / Principle

The question of inspection of unrelied-upon documents remains open, having been left open by the trial court, to be decided as and when such an application is filed.

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Detailed headnote1 paragraphs

Delhi High Court (CRL.M.C. 2483/2022, Justice Ravinder Dudeja, 27.11.2025): The Directorate of Enforcement had challenged a trial court order dated 22.03.2022 whose operative para 29 directed the ED to supply a list of material and documents collected during investigation but not forming part of the record, while keeping open the question of inspection of the entire seized material. Citing the Supreme Court decision in Sarla Gupta and Another vs. Directorate of Enforcement [2025 INSC 645], the ED's Special Counsel stated that the ED would abide by the impugned order insofar as it required supply of the list of unrelied-upon documents, and sought permission to withdraw the petition. The Court took the statement on record, dismissed the petition as withdrawn, and directed the petitioner to comply with the impugned order within six weeks. The issue of inspection of unrelied-upon documents was noted as already left open by the trial court, to be decided when such an application is filed.

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$~1

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IN THE HIGH COURT OF DELHI AT NEW DELHI

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- CRL.M.C. 2483/2022 & CRL.M.A. 10401/2022 STAY

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DIRECTORATE OF ENFORCEMENT .....Petitioner

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Through: Mr. Zoheb Hossain, Spl. Counsel ED, Mr. Manish Jain, Spl. Counsel ED & Mr. Vivek Gurnani, Panel Counsel ED.

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versus

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KANWAR DEEP SINGH AND ORS .....Respondents Through:

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CORAM: HON'BLE MR. JUSTICE RAVINDER DUDEJA

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O R D E R % 27.11.2025

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In the present petition, Directorate of Enforcement has challenged the impugned order dated 22.03.2022. The operative part of the order reads as under:-

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“29. The ED is also likewise directed to supply a list of the material and documents collected during investigation but which do not form part of the record as has been prayed for and to indicate what documents or material out of the same would be necessary for further investigation. In the application it is also prayed that the applicants be allowed to inspect the entire material seized by ED during investigation. However, the said issue is kept open and after the list is supplied to the accused persons, they would be at liberty to move an appropriate application in that regard.”

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Mr. Zoheb Hossain, learned Special Counsel, who appears for the

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/12/2025 at 12:23:45

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Directorate of Enforcement, fairly states that in view of judgment of Hon’ble Supreme Court in Sarla Gupta and Another vs. Directorate of Enforcement [2025 INSC 645], Directorate of Enforcement shall abide by the impugned order insofar as, it directs the Directorate of Enforcement to supply the list of unrelied upon documents. He, therefore, seeks permission to withdraw the petition.

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The statement made by learned counsel on behalf of Directorate of Enforcement is taken on record and petition is dismissed as withdrawn with direction to the petitioner to make compliance of the impugned order within a period of six weeks.

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The issue with regard to inspection of unrelied upon documents is already left open, by the trial Court, to be decided as and when such application is filed.

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RAVINDER DUDEJA, J

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NOVEMBER 27, 2025 /vd/ma

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This is a digitally signed order.

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The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 01/12/2025 at 12:23:45

Directorate of Enforcement v. Kanwar Deep Singh and Ors.

Case brief

What is this about?

What did the court decide?

Directorate of Enforcement v. Kanwar Deep Singh and Ors.

Case brief

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