In Nagani Akram Mohammad Shafi v. Union of India & State of Maharashtra, the Bombay High Court on July 8, 2025, ruled that the Enforcement Directorate (ED) can validly register money laundering cases under the Prevention of Money Laundering Act, 2002 (PMLA), based on offences under the Bharatiya Nyaya Sanhita, 2023 (BNS), which replaced the Indian Penal Code (IPC). The applicant argued that since the PMLA Schedule still refers to IPC sections and not BNS, such cases are invalid. However, the Court held that PMLA adopts "legislation by reference," not by incorporation. Under Section 8(1) of the General Clauses Act, these references dynamically adapt to corresponding provisions in BNS. The Court emphasized that the PMLA’s intent is to target crime proceeds linked to serious offences, irrespective of section numbers. Though a July 2024 executive notification attempted to update legal references, the Court declared it legally ineffective. The applicant’s bail was denied, and ED’s case upheld.