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R. Subramanian v. The Assistant Director, Directorate of Enforcement Decided by the High Court of Madras reported at MANU/TN/5918/2018

In the present matter the High Court of Madras held that supplementary complaint can be filed based upon the further investigation, and after obtaining special permission for further investigation as provided for under the Code of Criminal Procedure, 1973, under Section 65 of the Prevention of Money Laundering Act, 2002 (PMLA) the Enforcement Directorate can complete the further investigation and file a supplementary complaint in consonance with Section 44 (1) (b) and 45 of the PMLA.

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