Can a person claim an equitable benefit from the money which an investigating agency has traced in an extortion operation carried out for a proscribed terrorist organisation?
That extraordinary question has now reached the Supreme Court in the case of an MBBS graduate whose college fees — totalling more than ₹1.13 crore — were seized by the National Investigation Agency after being traced, according to the investigation, to funds raised for the Communist Party of India (Maoist).
On September 3, a Bench of Justices Vikram Nath and Sandeep Mehta issued notice in Puja Kumari v. Union of India (SLP(C) No. 29658 of 2026). The matter arises from a June 17 judgment of the Madras High Court refusing to compel Chettinad Academy of Research and Education to issue Puja Kumari’s MBBS degree and course-completion certificate without payment of the fees afresh. The Supreme Court has not decided the merits and will hear the matter further.
The facts recorded by the Madras High Court are striking.
Puja had secured admission through the regular centralised process and successfully completed both the five-year curriculum and compulsory internship. During her course, ₹1,13,70,500 was periodically remitted towards her fees.
The NIA, however, during its investigation in RC No. 05/2021/NIA/RNC, traced those payments to funds allegedly raised through extortion for the proscribed CPI (Maoist). The amount paid to the college was subsequently seized.
Importantly, the High Court did not hold that Puja herself was a Maoist or an accused. It expressly recorded her contention that she had no connection with any terrorist organisation and noted that she had not been arrayed as an accused.
But the Court also recorded that her brother Tarun Kumar and paternal uncle Pradyuman Sharma were arrayed in the NIA charge-sheet as persons allegedly involved in raising extorted funds for the banned organisation. According to the judgment, the money transferred towards her medical education was directly traceable to those funds.
That brought the Court to the central question of equity.
Ordinarily, educational certificates cannot be held hostage merely for recovery of money. The High Court acknowledged that settled principle. But it described Puja’s case as an extraordinary factual situation involving national security, terrorist funding and seizure of criminal assets.
Once the NIA seized the amount from the institution, the Court reasoned, the college was effectively left without the fees for an education it had already provided.
The Bench consequently held that although the student was not personally an accused, she could not demand an equitable benefit flowing from proceeds identified as the fruits of crime. It permitted her to pay the institution through clean funds and obtain her certificates, while leaving remedies concerning the seized money open before the competent forum.
The Supreme Court will now test that conclusion.
The case offers an unusual window into an often unseen dimension of Left-Wing Extremism. Maoist violence does not sustain itself only through guns in forests. Its ecosystem requires money, and extortion networks are alleged to have generated enormous sums far away from an encounter site.
At the same time, constitutional justice demands individual responsibility: guilt cannot travel merely through blood relations.
The challenge before the Supreme Court, therefore, is a delicate one — protecting an innocent individual’s future without permitting allegedly terror-tainted wealth to acquire legitimacy merely because it has travelled through the banking system and entered an educational institution.
