Galaxy International Hotels Llp vs Initiating Officer (Nct Of Delhi) & Anr on 29 April, 2026

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    Delhi High Court – Orders

    Galaxy International Hotels Llp vs Initiating Officer (Nct Of Delhi) & Anr on 29 April, 2026

    Author: Purushaindra Kumar Kaurav

    Bench: Purushaindra Kumar Kaurav

                              $~112 & 102
                              *         IN THE HIGH COURT OF DELHI AT NEW DELHI
                              +         W.P.(C) 5886/2026, & CM APPL. 28896/2026
    
                                        GALAXY INTERNATIONAL HOTELS LLP                                                   .....Petitioner
                                                                      Through:            Mr. Rohit Jain, Mr. Saksham Singhal,
                                                                                          Mr. Ram Krishna Rao, Advs.
    
                                                                      versus
    
                                        INITIATING OFFICER (NCT OF DELHI) & ANR. .....Respondents
                                                       Through: Mr. Counsel (appearance not given)
                              102
                              +         W.P.(C) 5834/2026 & CM APPL. 28666/2026
    
                                        EDGE INFRATECH LLP                                                                     .....Petitioner
                                                                      Through:            Mr. Rohit Jain, Mr. Saksham Singhal,
                                                                                          Mr. Ram Krishna Rao, Advs.
                                                                      versus
    
                                  INITIATING OFFICER (NCT OF DELHI) & ANR. .....Respondents
                                                 Through: Mr. Counsel (appearance not given)
                              CORAM:
                              HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV
                                                                      ORDER
    

    % 29.04.2026
    CM APPL. 28895/2026 & CM APPL. 28667/2026

    1. Exemptions allowed, subject to all just exceptions.

    SPONSORED

    2. Application stands disposed of.

    W.P.(C) 5886/2026, & CM APPL. 28896/2026
    W.P.(C) 5834/2026 & CM APPL. 28666/2026

    3. The petitioners seek for setting aside the order dated 10.07.2025

    This is a digitally signed order.

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    passed by the Appellate Tribunal under Smugglers and Foreign Exchange
    Manipulators (Forfeiture of Property) Act, 1976
    (SAFEMA) at New Delhi.

    4. It is the case of the petitioners that the said tribunal exercises the
    power of appellate tribunal under the provisions of the Prohibition of
    Benami Property Transactions Act, 1988
    (PBPTA). The review petition
    filed by initiating officer NCT of Delhi, Benami prohibition, unit 1, has been
    allowed.

    5. The facts would indicate that in year 2018, respondent no. 1 initiated
    the proceedings under the PBPTA against the petitioner and provisionally
    attached the petitioners’ properties under Section 24(3) of the PBPTA
    alleging that the petitioners were ‘benamidar’. The said attachment was
    confirmed by the adjudicating authority under Section 26(3) of the PBPTA
    Act on 20.04.2020.

    6. The respondents had invoked Section 24 of the PBPTA Act which
    was introduced in the year 2016, vide the Prohibition of Benami Property
    Transactions (Amendment) Act, 2016
    .

    7. The petitioners filed appeals before the appellate tribunal against the
    attachment order and the same was allowed vide order dated 30.11.2022 on
    the ground that that the Supreme Court, in Union of India and Another vs.
    Ganpati Dealcom Pvt. Ltd1 (Ganpati I
    ), had declared that, 2016
    Amendments, to the PBPTA, would have prospective effect and therefore,
    the transaction which took place prior to the said amendments could not be
    covered.

    8. In the year 2024, the Supreme Court, in Union of India and Another

    1
    [2023] 3 SCC 315

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    vs. Ganpati Dealcom Pvt. Ltd.2 (Ganpati II), has reviewed the said
    judgment
    and paragraph nos. 6 and 7 has held as under:

    “6. A challenge to the constitutional validity of a statutory provision
    cannot be adjudicated upon in the absence of a lis and contest between
    the parties. We accordingly allow the review petition and recall the
    judgment dated August 23, 2022 [Union of India v. Ganpati Dealcom
    Pvt. Ltd.
    , (2022) 447 ITR 108 (SC); (2023) 3 SCC 315; (2023) 1 SCC
    (Cri) 798; 2022 SCC OnLine SC 1064.] .
    Civil Appeal No 5783 of 2022
    [Union of India v. Ganpati Dealcom Pvt. Ltd., (2022) 447 ITR 108 (SC);
    (2023) 3 SCC 315; (2023) 1 SCC (Cri) 798; 2022 SCC OnLine SC
    1064.] shall stand restored to file for fresh adjudication before a Bench
    to be nominated by the Chief Justice of India on the administrative side.

    7. Where any other proceedings have been disposed of by relying on the
    judgment of this court in Union of India v. Ganpati Dealcom Pvt.

    Ltd. [(2022) 447 ITR 108 (SC); (2023) 3 SCC 315; (2023) 1 SCC (Cri)
    798; 2022 SCC OnLine SC 1064.] , liberty is granted to the aggrieved
    party to seek a review in view of the present judgment.”

    9. It is, thus, seen that, the decision in Ganpati I has been recalled by
    the Supreme Court in Ganpati II. The Supreme Court, in terms of paragraph
    no. 7 of Ganptai II has granted liberty to the aggrieved parties to seek a
    review where any other proceedings have been disposed of by relying on the
    judgment of the Supreme Court in the case of Ganpati I.

    10. It appears that on the basis of the liberty granted by the Supreme
    Court, the authority has approached the appellate tribunal seeking review of
    the decision passed in the case of the petitioner. The petitioners’ proceedings
    were dropped on the anvil of the principles laid down in a decision which
    has already been recalled by the Supreme Court. The final adjudication as to
    whether the provisions will have retrospective applicability or they will have
    to apply only with prospective effect, is yet to be rendered by the Supreme
    Court.

    2

    [2024] SCC OnLine SC 2981

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    11. Learned counsel appearing on behalf of the petitioner points out that
    subsequent to recall of Ganpati I, the similar controversy had arose in the
    case of Deputy Director of Income Tax (BPU Unity) and Ors. v.
    KokilabenChhaganbhai Patel3
    , before the division Bench of the Supreme
    Court. It is, thus, pointed out that the Division Bench has expressed its
    inability to agree with the liberty granted by the three judge Bench of the
    Supreme Court in Ganpati II.

    12. The Division Bench while relying on Govt. of NCT of Delhi vs. K.L.
    Rathi Steels Limited4
    which was also the three judge Bench judgment found
    that, the fact that the decision on a question of law on which the judgment of
    the Court is based has been reversed or modified by a subsequent decision of
    a superior court, in any other case shall not be a ground for a review of such
    judgment. It is, thus, submitted that in term of paragraph no. 5 following
    K.L. Rathi Steels Limited, the liberty was declined to seek for a review in
    that case
    .

    13. Paragraph no. 5 of the KokilabenChhanganbhai Patel is extracted as
    under:

    “5. In R.P.(C) No. 359 of 2023 in C.A. No. 5783 of 2022 (supra), a three-
    Judge Bench of this Court has failed to notice the judgment of this Court
    in K.L. Rathi Steels Limited (supra) which is also of a co-equal strength
    and prior in time.
    Therefore, following the judgment of this Court in K.L.
    Rathi Steels Limited
    (supra), we decline to grant liberty to seek review in
    the present case. Hence, the Review Petition is dismissed.”

    14. It is also pointed out that following the same line of reasoning, the
    division Bench of the Guwahati High Court in the case of Satyajit Saha vs.

    3
    2025 SCC OnLine SC 2622
    4
    [2024] 7 SCC 315

    This is a digitally signed order.

    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 30/04/2026 at 21:49:42
    UOI5 has set aside the decision of review. Paragraph nos. 24 to 26 of the
    Guwahati High Court decision is extracted as under:

    “24. This observation had been made by the two Judges Bench by taking
    the support of the earlier judgment of another three Judges Bench of the
    Supreme Court in K.L. Rathi Steels Limited (supra).
    Further, the two
    Judges Bench in Kokilaben Chhaganbhai Patel (supra) had held that the
    three Judges Bench of the Supreme Court, while disposing the review
    petition in Union of India v. Ganpati Dealcom Private Limited, (2025)
    474 ITR 354 : 2024 SCC OnLine SC 2981 had failed to notice the
    judgment of the earlier judgment of the three Judges Bench in K.L. Rathi
    Steels Limited
    (supra).

    25. As can be seen from the above facts, the Hon’ble Supreme Court in
    the case of Kokilaben Chhaganbhai Patel (supra), has already taken a
    decision with regard to which of the three Judges Benches decision of the
    Hon’ble Supreme Court should be followed.
    It has already decided that
    the earlier three Judges Bench in the case of K.L. Rathi Steels
    Limited
    (supra) would have to be followed and the observation/direction
    passed in paragraph-7 of the review petition in Union of India v. Ganpati
    Dealcom Private Limited
    , (2025) 474 ITR 354 : 2024 SCC OnLine SC
    2981 cannot be followed, as the same was apparently per incuriam.

    When the Hon’ble Supreme Court in the case of Kokilaben Chhaganbhai
    Patel
    (supra) has already decided as to which decision of the conflicting
    3 Judges Bench is to be followed, we are bound to follow the above
    interpretation given by the Hon’ble Supreme Court.
    Further, in the case
    of National Insurance Company Limited v. Pranay Sethi, (2017) 16 SCC
    680 : (2018) 2 SCC (Cri) 205 : (2018) 3 SCC (Civ) 248, the Hon’ble
    Supreme Court has held that when there are conflicting decisions of
    equal Benches of the Supreme Court, the earlier decision would have to
    be followed by the High Court.

    26. In view of the reasons stated above, the following Questions of Law
    are answered as follows:

    1. Whether the Learned Tribunal acted illegally in allowing the Review
    Petition on the basis of the liberty granted by the Supreme Court, without
    examining whether such liberty could override the statutory limitations
    under Section 114 read with Order 47 CPC, 1908 and
    Section 40(2)(f) PBPT Act?

    2. Whether the impugned order allowing the review application is in teeth of
    the express bar set forth in Explanation in Rule 1 of Order 47?

    Answer–

    5

    [2026] SCC OnLine Gau 1327

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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 30/04/2026 at 21:49:42
    In terms of the judgment of the Supreme Court in K.L. Rathi Steels
    Limited
    (supra) and Kokilaben Chhaganbhai Patel (supra), the learned
    Appellate Tribunal could not have allowed the review petition only on the
    basis of the liberty granted by the Hon’ble Supreme Court in Union of
    India v. Ganpati Dealcom Private Limited
    , (2025) 474 ITR 354 : 2024
    SCC OnLine SC 2981, without taking a decision as to whether the
    provisions of Order 47 of the CPC was attracted.”

    15. The Court prima-facie finds that the review which has been
    entertained by the appellate tribunal cannot be held to be wholly unjustified
    or completely without jurisdiction, as the same is in consonance with the
    binding and applicable directions in Ganpati II. It is not a case of
    subsequent overruling. In the instant case Ganpati I, itself has been
    recalled. Distinction has to be drawn from the cases, where, the decisions are
    overruled and the one, where, decision itself has been recalled. Despite
    directions in Ganpati II, if review is not entrained, the same would amount
    to violation of the Supreme Court directions. The Ganpati II, has not been
    recalled. These aspects have to be considered in greater detail.

    16. On petitioners’ taking necessary steps, let notice be issued to all
    respondents by all permissible modes, returnable on 01.09.2026.

    17. However, till the matter is further heard, the Court needs to stay the
    final decision to be rendered by the Tribunal. Let the proceedings continue,
    however, no final order shall be passed till further orders.

    PURUSHAINDRA KUMAR KAURAV, J
    APRIL 29, 2026/SH

    This is a digitally signed order.

    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 30/04/2026 at 21:49:42



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