IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 9^TH DAY OF MARCH, 2026 PRESENT THE HON'BLE MRS. JUSTICE ANU SIVARAMAN AND THE HON'BLE MR. JUSTICE VIJAYKUMAR A. PATIL WRIT APPEAL NO. 492 OF 2026 (GM-RES)

BETWEEN:

DIRECTORATE OF ENFORCEMENT MINISTRY OF FINANCE DEPARTMENT OF REVENUE GOVERNMENT OF INDIA HMT FACTORY PREMISES NEAR HMT CINEMA 4K D.RAJAGOPALA CIRCLE JALAHALLI-560 013.

...APPELLANT (BY SRI. KULOOR ARVIND KAMATH, ASGI WITH SRI. MADHU N RAO, ADVOCATE AND SPP FOR THE ENFORCEMENT DIRECTORATE)

AND:

ZO PVT LTD A COMPANY INCORPORATED UNDER THE COMPANIES ACT, 2013 HAVING ITS REGISTERED OFFICE AT No.55, 2^ND FLOOR, LANE-2 WESTEND MARG, SAIDULLAJAB NEAR SAKET METRO STATION GADAIPUR, SOUTH-WEST DELHI NEW-DELHI, DELHI INDIA-110 030. ...RESPONDENT (BY SRI. SAJAN POOVAYYA, SENIOR ADVOCATE FOR SRI. ROHAN KOTHARI, ADVOCATE FOR C/R)

THIS WRIT APPEAL IS FILED U/S 4 OF THE KARNATAKA HIGH COURT ACT, 1961, PRAYING TO (a) SET ASIDE THAT PART OF THE ORDER NAMELY "B", "C" AND "D" DATED 02.02.2026 PASSED BY THE LEARNED SINGLE JUDGE, HIGH COURT OF KARNATAKA, BENGALURU IN WP No.962/2026 AND ETC.

THIS WRIT APPEAL HAVING BEEN HEARD AND RESERVED FOR JUDGMENT ON 23.02.2026 AND COMING ON FOR PRONOUNCEMENT OF JUDGMENT THIS DAY, ANU SIVARAMAN J., PRONOUNCED THE FOLLOWING:

CORAM: HON'BLE MRS. JUSTICE ANU SIVARAMAN and HON'BLE MR. JUSTICE VIJAYKUMAR A. PATIL

CAV JUDGMENT

(PER: HON'BLE MRS. JUSTICE ANU SIVARAMAN)

This writ appeal is preferred by the Directorate of Enforcement challenging the Order dated 02.02.2026, passed by the learned Single Judge in W.P.No.962/2026 (GM-RES).

2. We have heard Shri. Kuloor Arvind Kamath, learned Additional Solicitor General of India with Shri. Madhu N. Rao, learned Special Public Prosecutor, appearing for the appellant and Shri. Sajan Poovayya, learned senior counsel as instructed by Shri. Rohan Kothari, learned advocate appearing for the caveator/respondent.

3. The learned Additional Solicitor General of India (ASGI) appearing for the appellant - Authority submits that the bank accounts of the respondent - Zo Private Limited have been frozen under Section 17(1A) of the Prevention of Money Laundering Act, 2002 ('PMLA' for short) by an Order dated 30.12.2025. It is submitted that the learned Single Judge refused to interfere in the Order freezing the accounts and the writ petition was disposed of with liberty to Zo Private Limited to contest the proceedings before the Adjudicating Authority against the continuance of the freeze of its account. However, Zo Private Limited was permitted to file a list of employees to whom salaries have to be paid for the month of January, 2026 and the appellant was directed to verify the list and communicate to the Bank, forthwith, to enable Zo Private Limited to pay salaries to the employees for the month of January, 2026. It is further submitted that the scope of proceedings under the PMLA is such that any adjudication as to whether an Order under Sections 5 or 17 of the PMLA is required to be continued is subject to an adjudication before the Adjudicating Authority as provided under the PMLA.

4. It is contended that the appellant recorded Enforcement Case Information Report (ECIR) as per assigned format No.ECIR/BGZO/25/2025 dated 06.11.2025 against Winzo Games Private Limited and others for investigation of the offence of money laundering under Section 3 read with Section 4 of the PMLA. The ECIR was registered on the basis of materials relating to multiple scheduled offences/FIRs registered in different States alleging cheating, forgery, conspiracy, and fraud in relation to the real money gaming operations of Winzo Games Private Limited.

5. It is further contended that the searches under Section 17 of the PMLA were conducted from 18.11.2025 to 22.11.2025 and 30.12.2025. The investigation allegedly revealed fraudulent practices and manipulation of gaming outcomes causing financial loss to users. Thereafter, the appellant recorded that Winzo Games Private Limited had generated total proceeds