The Supreme Court reconstituted the bench hearing review petitions against the Vijay Madanlal Choudhary judgment, which in 2022 upheld sweeping PMLA powers including arrest without warrant and a reversed burden of proof. Justices Ujjal Bhuyan and N.K. Singh were replaced by Justices Joymalya Bagchi and V. Mohana by parties' consent. The reconstitution keeps the review alive and signals the bench will now proceed afresh on challenges to PMLA's foundational provisions.

The Vijay Madanlal Choudhary v. Union of India (2022) judgment is one of the most consequential Supreme Court rulings on money-laundering law. A three-judge bench upheld nearly all of the Enforcement Directorate's extraordinary powers under the Prevention of Money Laundering Act, 2002: the power to arrest without a magistrate's order (Section 19), the twin conditions for bail (Section 45), the admissibility of ED statements (Section 50), and the reversed burden of proof requiring the accused to prove innocence.

Review petitions challenging this ruling have been pending, and the bench composition has now changed by consent of parties — a procedurally important fact because it means no party objected, signalling agreement that fresh judges can re-examine the record without a fresh hearing from scratch.

For CLAT PG, the examiner treats PMLA as a static anchor: the sections, the constitutional challenges, and the Supreme Court's reasoning are tested repeatedly. The key doctrinal points the examiner extracts are: (a) whether PMLA bail conditions survive Article 21 scrutiny, (b) the 'proceeds of crime' definition and its scope, (c) the ED's power under Section 50 versus the right against self-incrimination under Article 20(3), and (d) the distinction between a scheduled offence and the PMLA offence itself. The reconstitution of the bench keeps all these issues live and makes the judgment's status — upheld but under review — a testable procedural fact.