The Madras High Court's recent judgment in Rhutikumari v. Zanmai Labs Pvt. Ltd. delivered on October 25, 2025, represents a watershed moment in Indian cryptocurrency jurisprudence. Justice N. Anand Venkatesh's comprehensive order not only addresses the immediate concerns of a crypto investor whose assets were frozen following a cyberattack but also establishes foundational principles for how Indian courts will treat digital assets in the evolving Web3 landscape. This 5,000-word analysis examines the judgment's legal reasoning, its implications for India's cryptocurrency ecosystem, and offers critical perspectives on its strengths and limitations.

Background and Factual Matrix

The Parties and the Platform

The case arose from a dispute between Rhutikumari, an individual investor, and Zanmai Labs Pvt. Ltd., an Indian company incorporated under the Companies Act, 2013, along with its directors. Zanmai Labs operates WazirX, India's leading cryptocurrency exchange platform that boasted over 60 million registered users, of whom 4.3 million maintained active crypto balances.Rhutikumari_Vs_Zanmai_Labs.pdf​

The corporate structure underlying WazirX reveals a complex web of ownership and operational control. Zanmai Labs functions as a wholly-owned subsidiary of Zettai Pte. Ltd. (formerly Zanmai Pte Ltd.), a Singaporean entity. The platform's operational history adds further complexity: in November 2019, Binance announced its acquisition of WazirX and entered into a licensing and distribution agreement with Zanmai Labs. Under this arrangement, Zanmai Labs served as a non-exclusive distributor for trading services involving Indian Rupees and cryptocurrencies within India, while Binance operated the cryptocurrency-related infrastructure.Rhutikumari_Vs_Zanmai_Labs.pdf​

This relationship deteriorated in August 2022 when Binance began distancing itself from the platform, culminating in the termination of wallet and technology support on January 26, 2023. Following Binance's withdrawal, Zettai assumed custody of the cryptocurrency assets and entered into a licensing agreement with Liminal Infrastructure (Answer Eleven Pte. Ltd.) on January 31, 2023, to provide digital asset wallet management services.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Investment and the Cyberattack

In January 2024, Rhutikumari invested ₹1,98,516 in the WazirX platform, purchasing 3,532.30 XRP coins. These coins were stored in a wallet maintained by the platform, with the applicant assigned a specific client identification number (1709079) linked to her email address and mobile number. The value of these XRP coins fluctuated with market conditions; by January 17, 2025, they were worth ₹9,55,148.20.Rhutikumari_Vs_Zanmai_Labs.pdf​

The crisis began on July 18, 2024, when WazirX announced that one of its cold wallets had been subjected to a cyberattack. The attack specifically targeted Ethereum and Ethereum-based ERC-20 tokens, resulting in losses of approximately USD 230-235 million. Security analyses suggest the attack was orchestrated by North Korea's Lazarus Group, which exploited vulnerabilities in WazirX's multi-signature wallet system managed through Liminal Infrastructure.fticybersecurity+2​Rhutikumari_Vs_Zanmai_Labs.pdf​

The attack methodology was sophisticated. The hackers manipulated the multi-signature wallet, which required four of six signatures (three from WazirX and one from Liminal) to authorize transactions. By exploiting discrepancies between how transactions appeared in the Liminal interface and the actual transaction data, attackers obtained the necessary signatures to change the wallet to a malicious smart contract they had deployed eight days earlier. This allowed them to bypass security protocols and drain the funds.halborn​

Following the announcement, WazirX immediately froze all user accounts, including Rhutikumari's, preventing her from accessing, trading, or liquidating her XRP coins. Critically, the cyberattack affected only ERC-20 tokens, not XRP coins, which were held in separate wallets.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Legal Framework and Arbitration Clause

The relationship between WazirX users and the platform was governed by a User Agreement dated August 1, 2023. This agreement contained an arbitration clause stipulating that disputes would be resolved under the rules of the Singapore International Arbitration Centre (SIAC) with Singapore as the seat of arbitration.Rhutikumari_Vs_Zanmai_Labs.pdf​

Following the cyberattack, Zettai initiated restructuring proceedings in Singapore under the Companies Act, proposing a scheme of arrangement to distribute losses among users. This scheme, which gained approval from 95.7% of voting creditors (representing 94.6% by value) in August 2025, proposed a "socialization of losses" whereby all users would bear a proportionate share of the losses caused by the cyberattack. The Singapore High Court sanctioned this modified scheme on October 13, 2025.mudrex+2​Rhutikumari_Vs_Zanmai_Labs.pdf​

Against this backdrop, Rhutikumari filed an application under Section 9 of the Arbitration and Conciliation Act, 1996, seeking an interim injunction to restrain the respondents from interfering with her XRP holdings through redistribution, apportionment, or reallocation.Rhutikumari_Vs_Zanmai_Labs.pdf​

Legal Issues and Arguments

Jurisdictional Challenge

The primary preliminary objection raised by Zanmai Labs challenged the Madras High Court's jurisdiction to entertain the Section 9 application. The respondents argued that since the arbitration agreement designated Singapore as the seat of arbitration with SIAC rules governing the proceedings, and considering that digital wallets were held outside India by a foreign entity (Zettai/Liminal), Indian courts lacked jurisdiction to grant interim relief.Rhutikumari_Vs_Zanmai_Labs.pdf​

Rhutikumari countered this objection by asserting that a part of the cause of action arose within the court's territorial jurisdiction. She transferred Indian Rupees from her Kotak Mahindra Bank account in George Town, Chennai, to purchase the cryptocurrencies, and she accessed and operated the WazirX platform through her mobile phone within the court's jurisdiction.Rhutikumari_Vs_Zanmai_Labs.pdf​

Nature of Cryptocurrency Holdings

The substantive legal issues centered on fundamental questions about the nature of cryptocurrency:

1. Whether cryptocurrency constitutes "property" under Indian law?

2. Whether crypto exchange platforms hold user assets as custodians or trustees?

3. Whether users are "investors" or "proprietors" of their cryptocurrency holdings?

4. Whether the Singapore scheme of arrangement binds Indian users whose assets were not affected by the cyberattack?

5. Whether losses from stolen ERC-20 tokens can be socialized across holders of different cryptocurrencies like XRP?

Arguments by the Parties

Applicant's Position:

Rhutikumari argued that Zanmai Labs held her XRP coins in its capacity as custodian and in trust on her behalf. She contended that her specific XRP holdings remained intact and unaffected by the cyberattack, which targeted only ERC-20 tokens in a different wallet. She sought protection for her property rights, arguing that the platform should not be permitted to dilute her holdings to compensate for losses she did not suffer.Rhutikumari_Vs_Zanmai_Labs.pdf​

The applicant emphasized that under Clause 6 of the User Agreement, Zanmai Labs was designated as the authorized entity for handling non-P2P transactions involving Indian Rupees and cryptocurrencies. Since Zanmai Labs was the only entity registered with India's Financial Intelligence Unit (FIU) as a reporting entity authorized to handle cryptocurrency in India, it bore primary responsibility for safeguarding user assets.Rhutikumari_Vs_Zanmai_Labs.pdf​

Respondents' Position:

Zanmai Labs and its directors presented a multi-pronged defense. First, they argued that the platform merely facilitated peer-to-peer trades and did not hold virtual digital assets as a custodian or trustee. They contended that the actual custody of crypto assets rested with foreign entities—first Binance, then Zettai, and subsequently Liminal Infrastructure. According to this theory, Zanmai Labs only managed the Indian Rupee leg of transactions through Indian banking channels, while the crypto assets remained under foreign custody.Rhutikumari_Vs_Zanmai_Labs.pdf​

Second, the respondents argued that the Singapore scheme of arrangement, approved by an overwhelming majority of creditors and sanctioned by the Singapore High Court, should bind all users. They contended that the "socialization of losses" represented a fair and equitable distribution mechanism overseen by a competent foreign court.Rhutikumari_Vs_Zanmai_Labs.pdf​

Third, they challenged Rhutikumari's intent to arbitrate, noting that she had not issued a trigger notice to initiate arbitration proceedings despite the passage of considerable time since the account freeze.Rhutikumari_Vs_Zanmai_Labs.pdf​

Court's Analysis and Reasoning

Jurisdictional Finding

Justice Venkatesh addressed the jurisdictional challenge by analyzing the proviso to Section 2(2) of the Arbitration and Conciliation Act, 1996, as interpreted by the Supreme Court in PASL Wind Solutions (P) Ltd. v. GE Power Conversion India (P) Ltd. (2021). The Supreme Court held that even where arbitration is seated outside India, Indian courts may exercise jurisdiction under Section 9 when:Rhutikumari_Vs_Zanmai_Labs.pdf​

1. At least one party to the arbitration agreement resides in India

2. Assets of one of the parties are situated in India

3. Interim orders are required for preservation of such assetsRhutikumari_Vs_Zanmai_Labs.pdf​

The Court held that Rhutikumari's cryptocurrency holdings constituted assets situated in India because she accessed and operated the WazirX platform through her mobile phone from her ordinary place of residence in India. The platform was operated within India, she had transferred Indian Rupees from an Indian bank account, and she was prevented from trading or liquidating her holdings through the India-based WazirX platform. Consequently, the Court concluded that it possessed jurisdiction to entertain the Section 9 application.Rhutikumari_Vs_Zanmai_Labs.pdf​

This finding is significant because it adopts a functional approach to asset location for digital assets. Rather than focusing on where blockchain nodes or private keys are physically stored, the Court emphasized where the beneficial owner exercises control and derives utility from the asset.Rhutikumari_Vs_Zanmai_Labs.pdf​

Cryptocurrency as Property: The Core Finding

The judgment's most significant contribution lies in its comprehensive analysis establishing cryptocurrency as "property" under Indian law. Justice Venkatesh embarked on an extensive exploration of this question, drawing on Indian constitutional jurisprudence, international precedents, and the technological nature of cryptocurrencies.Rhutikumari_Vs_Zanmai_Labs.pdf​

Definitional Framework:

The Court began by acknowledging the Supreme Court's observation in Internet and Mobile Association of India v. Reserve Bank of India (2020) that defining virtual currency follows a "neti, neti" (not this, not that) approach—an expression borrowed from Vedic philosophy for capturing the essence of something inexpressible. The Court recognized that cryptocurrency is neither currency stricto sensu nor an asset in the traditional sense.Rhutikumari_Vs_Zanmai_Labs.pdf​

The judgment explained that cryptocurrencies are "streams of 1s and 0s residing in a blockchain managed by the issuer of the cryptocurrency". Each unit is created through data mining and problem-solving that adds to the blockchain, rather than through central banking decisions. The cryptocurrency itself resides where the blockchain is located.Rhutikumari_Vs_Zanmai_Labs.pdf​

Digital assets are stored and recorded on blockchain ledgers where they were issued, with each ledger entry having associated public and private keys. Digital wallets store these keys securely, enabling access to the assets, but the assets themselves remain on the blockchain.Rhutikumari_Vs_Zanmai_Labs.pdf​

Legal Conception of Property:

To determine whether cryptocurrency qualifies as property, the Court examined the meaning of "property" in Indian jurisprudence. It relied primarily on two Supreme Court decisions:

Ahmed G.H. Ariff v. CWT (1969): This case held that "property" is a term of widest import that "signifies every possible interest which a person can clearly hold or enjoy". The Supreme Court had given an expansive interpretation, extending the concept to include interests with the "insignia or characteristic of proprietary right" even if they didn't fit traditional property categories.Rhutikumari_Vs_Zanmai_Labs.pdf​

Jilubhai Nanbhai Khachar v. State of Gujarat (1995): This case defined property in legal terms as "an aggregate of rights which are guaranteed and protected by law," extending to "every species of valuable right and interest". The decision emphasized that property "connotes everything which is subject of ownership, corporeal or incorporeal, tangible or intangible, visible or invisible, real or personal; everything that has an exchangeable value or which goes to make up wealth or estate or status".Rhutikumari_Vs_Zanmai_Labs.pdf​

Applying these principles, Justice Venkatesh concluded: "There can be no doubt that 'crypto currency' is a property. It is not a tangible property nor is it a currency. However, it is a property, which is capable of being enjoyed and possessed (in a beneficial form). It is capable of being held in trust".Rhutikumari_Vs_Zanmai_Labs.pdf​

International Precedents:

The Court buttressed its conclusion by examining how courts in other jurisdictions have treated cryptocurrencies:

United Kingdom: In AA v. Persons Unknown (2019), the UK High Court held that Bitcoin could be considered a form of property capable of ownership and transfer.Rhutikumari_Vs_Zanmai_Labs.pdf​

Singapore: Following UK precedent, Singapore courts in Janesh v. Unknown Person (2022) and ByBit Fintech Ltd. v. Ho Kai Xin (2023) confirmed that digital tokens can be defined, identified, transferred, and stored like any other form of property.Rhutikumari_Vs_Zanmai_Labs.pdf​

United States: US courts have focused on classification issues. In SEC v. Ripple Labs Inc. (2023), the court examined whether XRP tokens (the very cryptocurrency involved in the present case) qualified as securities under the Howey Test. The court ruled that XRP tokens sold in public markets were not securities, though institutional sales were. In CFTC v. My Big Coin Pay, Inc. (2018), a federal court held that cryptocurrencies can be classified as commodities under the Commodity Exchange Act.Rhutikumari_Vs_Zanmai_Labs.pdf​

New Zealand: The Court gave particular attention to Ruscoe v. Cryptopia Ltd. (in Liquidation) (2020), where the New Zealand High Court held that cryptocurrencies, as digital assets, are a form of property capable of being held on trust. The Cryptopia case is particularly relevant because it involved a cryptocurrency exchange (similar to WazirX) that was hacked, with liquidators seeking guidance on asset distribution.Rhutikumari_Vs_Zanmai_Labs.pdf​

The New Zealand court held that cryptocurrencies are "a type of intangible property" resulting from the combination of three interdependent features: (1) they obtain their definition from the public key recording the unit of currency; (2) control and stability necessary for ownership are provided by the private key and generation of fresh keys upon transfer. Though "only a series of 1s and 0s," it is "more than mere information"—it is property capable of being held on trust.Rhutikumari_Vs_Zanmai_Labs.pdf​

Statutory Recognition in India:

The Court noted that under Indian law, cryptocurrency is treated as a "virtual digital asset" governed by Section 2(47A) of the Income Tax Act, 1961. This statutory recognition indicates that the legislature has acknowledged cryptocurrency as an asset capable of being owned, stored, traded, and sold—not as a speculative transaction.Rhutikumari_Vs_Zanmai_Labs.pdf​

Custodial Relationship and Fiduciary Duty

Having established cryptocurrency as property, the Court examined the relationship between WazirX and its users. Contrary to the respondents' argument that they merely facilitated peer-to-peer transactions without custodial responsibility, the Court found that the platform held user assets as a custodian with fiduciary duties.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Court analyzed Clause 6 of the User Agreement, which explicitly covered non-P2P transactions where Indian residents deposit Indian Rupees and receive cryptocurrency. Under this clause, Zanmai Labs enabled users to trade in pairs involving Indian Rupees and supported cryptocurrencies (e.g., INR-BTC, INR-ETH). The agreement designated Zanmai Labs as the agent for Indian users.Rhutikumari_Vs_Zanmai_Labs.pdf​

Critically, the Court noted that Zanmai Labs was the only entity registered as a reporting entity with India's Financial Intelligence Unit, thereby authorized to handle cryptocurrency in India. Neither Zettai nor Binance possessed such authorization. This regulatory registration indicated that Zanmai Labs bore primary responsibility for Indian users' crypto assets, regardless of where the underlying blockchain infrastructure was located.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Bombay High Court Precedent

Justice Venkatesh drew extensively from the Bombay High Court's decision in Zanmai Labs Private Limited v. Bitcipher Labs LLP (2025), which involved similar facts. In that case, the Bombay High Court had upheld an arbitral tribunal's order granting interim protection to crypto users whose assets were frozen after the WazirX cyberattack.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Bombay High Court made several key findings that the Madras High Court adopted:

1. Rejection of Loss Socialization: The Bombay court held that the "socialization of losses" proposed by Zettai's Singapore scheme lacked contractual foundation. The scheme was "nothing but a proposal to spread the losses arising out of the cyber-attack across multiple users of the platform somewhat like a group insurance of a self-help group," but "the basis of such a proposition is not any term in the contractual framework between the parties".Rhutikumari_Vs_Zanmai_Labs.pdf​

2. Custodial Accountability: The court emphasized that when assets are held in custody under an agreement, the custodian is accountable for those assets. "It would not be open for that person to state that the assets were handed over by him to yet another person without the consent of the person whose assets were handed over to him in custody".Rhutikumari_Vs_Zanmai_Labs.pdf​

3. Differential Treatment Based on Asset Type: Most significantly, the Bombay court recognized that assets not subjected to the cyberattack should not be subjected to a "haircut" (proportionate loss allocation). Since the attack compromised ERC-20 tokens specifically, the tribunal allowed only a 45% haircut to users' ERC-20 exposure, protecting other cryptocurrencies from loss socialization.Rhutikumari_Vs_Zanmai_Labs.pdf​

4. Inadequacy of Force Majeure Defense: While acknowledging that a cyber-attack could constitute a force majeure event, the court questioned whether such an event could "erode the very assets legitimately held by the users". The court distinguished between suspending services (trading ability) and eroding the underlying asset value—the former might be justified by force majeure, but the latter required contractual or legal basis.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Madras High Court expressly agreed with these findings, stating: "This Court is in complete agreement with the above findings rendered by the Bombay High Court wherein it was held that the virtual digital asset held electronically are meant to be held in trust with a fiduciary duty owed to the owners of such asset".Rhutikumari_Vs_Zanmai_Labs.pdf​

Application to Rhutikumari's Case

Applying these principles, Justice Venkatesh identified a "moot question": whether ERC-20 coins stolen in the cyberattack, which were held in a separate wallet, could be adjusted against a completely different cryptocurrency (XRP coins) held by the applicant in a different wallet.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Court held that this fundamental question should be adjudicated by the arbitral tribunal, but that pending such adjudication, the applicant—as a vulnerable party whose assets faced substantial erosion—was entitled to interim protection. The vulnerability arose because under the Singapore scheme, assets unaffected by the hack would be diluted to compensate for losses of different assets that were compromised.Rhutikumari_Vs_Zanmai_Labs.pdf​

Binding Effect of Singapore Scheme

The respondents argued that the Singapore scheme, approved by 95.7% of voting creditors, should bind all users including Rhutikumari. The Court rejected this argument at the interim stage, holding that "whether the order dated 13.10.2025 passed by the Singapore High Court will bind the applicant, whose asset is going to stand eroded, is a larger issue, which will be dealt with by the Arbitral Tribunal".Rhutikumari_Vs_Zanmai_Labs.pdf​

This finding respects principles of party autonomy and arbitration while protecting individual property rights. The Court recognized that the majority vote in Singapore could not ipso facto override the proprietary rights of an Indian resident whose specific assets were not affected by the breach, especially when those rights are subject to arbitration under the parties' agreement.Rhutikumari_Vs_Zanmai_Labs.pdf​

Intent to Arbitrate

The respondents contended that Rhutikumari lacked manifest intention to arbitrate because she had not issued a trigger notice to initiate arbitration. The Court rejected this objection, noting that the applicant reasonably awaited clarity on the Singapore proceedings before initiating arbitration. The Singapore High Court had initially rejected the scheme in May 2025, only sanctioning a modified version in October 2025. The Court held that the applicant would now issue a trigger notice, having gained clarity on her position following the Singapore court's final order.Rhutikumari_Vs_Zanmai_Labs.pdf​

Final Order and Relief Granted

The Court granted interim relief under Section 9 of the Arbitration and Conciliation Act, directing the first respondent (Zanmai Labs) to either:

1. Furnish a bank guarantee for ₹9,56,000 (approximately the value of the XRP holdings) in favor of the applicant, to be renewed until the end of arbitration proceedings; OR

2. Deposit the said sum in escrow for preservation of the subject matter until arbitration concludesRhutikumari_Vs_Zanmai_Labs.pdf​

This order ensures that the applicant's asset value is preserved pending final adjudication of her rights by the arbitral tribunal.Rhutikumari_Vs_Zanmai_Labs.pdf​

Critical Analysis and Interpretation

Strengths of the Judgment

1. Comprehensive Legal Framework:

The judgment's greatest strength lies in its comprehensive analysis of cryptocurrency as property. Rather than offering a cursory treatment, Justice Venkatesh engaged deeply with the technological nature of blockchain assets, international jurisprudence, Indian constitutional law, and statutory frameworks. This multidimensional approach provides a robust foundation for future cryptocurrency litigation in India.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Court's reliance on the expansive definition of property from Jilubhai Nanbhai Khachar and Ahmed G.H. Ariff was particularly apt. By emphasizing that property encompasses "every species of valuable right and interest" and "everything that has an exchangeable value," the Court avoided the trap of requiring cryptocurrencies to fit within traditional property categories. This flexible approach accommodates the unique characteristics of digital assets while remaining anchored in established legal principles.Rhutikumari_Vs_Zanmai_Labs.pdf​

2. Recognition of Technological Realities:

The judgment demonstrates sophisticated understanding of blockchain technology, distinguishing between the asset itself (which resides on the blockchain), the keys that provide access (stored in digital wallets), and the interface through which users exercise control (the exchange platform). This technical literacy enabled the Court to make nuanced findings about asset location and custodial relationships.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Court's functional approach to determining asset location for jurisdictional purposes reflects appreciation of how users actually interact with cryptocurrencies. By focusing on where the applicant accessed and controlled her assets, rather than the physical location of servers or blockchain nodes, the Court adopted a user-centric framework appropriate for digital assets.Rhutikumari_Vs_Zanmai_Labs.pdf​

3. Protection of Individual Property Rights:

The judgment properly balances collective interests (as expressed through the Singapore creditors' vote) against individual property rights. The Court recognized that majority approval of a loss socialization scheme cannot automatically override the property rights of an individual whose specific assets were not compromised. This protection is particularly important in the cryptocurrency context, where exchanges hold diverse assets for millions of users, and system-wide schemes might unfairly impact users based on the specific assets they hold.Rhutikumari_Vs_Zanmai_Labs.pdf​

The differentiation between ERC-20 tokens (which were stolen) and XRP coins (which were not) demonstrates proper attention to the fungibility limitations of different cryptocurrencies. Unlike traditional currency where one rupee is identical to another, different cryptocurrencies represent distinct property interests with separate risk profiles and values.Rhutikumari_Vs_Zanmai_Labs.pdf​

4. International Precedent Integration:

The Court's examination of UK, Singapore, New Zealand, and US precedents demonstrates engagement with emerging global consensus on cryptocurrency's legal status. This comparative approach is valuable because cryptocurrency regulation and jurisprudence are developing simultaneously across jurisdictions, and cross-pollination of legal concepts can accelerate doctrinal development.Rhutikumari_Vs_Zanmai_Labs.pdf​

The particular attention given to Ruscoe v. Cryptopia Ltd. was well-placed, as that case presented nearly identical factual circumstances—a cryptocurrency exchange hacked, users' assets frozen, and questions about property rights and trust relationships. The New Zealand court's careful analysis of how public and private keys create property interests provides a model that the Madras High Court wisely adopted.Rhutikumari_Vs_Zanmai_Labs.pdf​

5. Balancing Interim Relief with Arbitration:

The Court demonstrated judicial restraint by granting interim protection while reserving substantive questions for the arbitral tribunal. This approach respects the parties' arbitration agreement while ensuring that the subject matter of arbitration is preserved. The Court did not finally determine whether the Singapore scheme binds Rhutikumari or whether loss socialization is permissible—it merely ensured she would not be irreparably harmed before those questions could be adjudicated.Rhutikumari_Vs_Zanmai_Labs.pdf​

Criticisms and Limitations

1. Incomplete Analysis of Regulatory Framework:

While the judgment acknowledges that cryptocurrency is governed as a "virtual digital asset" under Section 2(47A) of the Income Tax Act, 1961, it does not extensively analyze India's broader regulatory approach to cryptocurrency. The Reserve Bank of India's 2018 ban on banks providing services to cryptocurrency businesses was struck down by the Supreme Court in Internet and Mobile Association of India v. RBI (2020), but significant regulatory uncertainty persists.Rhutikumari_Vs_Zanmai_Labs.pdf​

The judgment notes that WazirX was registered with the Financial Intelligence Unit as a reporting entity, but does not explore what regulatory obligations this registration entails or how it affects custodial relationships. The Prevention of Money Laundering Act (PMLA) requires reporting entities to maintain certain standards for customer due diligence and transaction reporting, but the judgment does not examine whether these obligations create statutory duties that reinforce the fiduciary relationship the Court found.Rhutikumari_Vs_Zanmai_Labs.pdf​

2. Limited Discussion of Smart Contract Implications:

The judgment describes how the hackers exploited the multi-signature wallet by substituting a malicious smart contract, but does not deeply analyze the legal implications of smart contract-based custody arrangements. In blockchain systems, "code is law"—the smart contract's programmed rules determine how assets can be moved. When users deposit cryptocurrency in an exchange, they typically relinquish direct control to the exchange's smart contracts.Rhutikumari_Vs_Zanmai_Labs.pdf​

This technical reality complicates the custodial relationship. If the smart contract itself is compromised (as occurred here), can the exchange be held fully liable despite having implemented industry-standard security measures? The judgment's finding that Zanmai Labs bore custodial responsibility is sound, but more extensive analysis of how smart contract vulnerabilities affect custodial liability would have been valuable.

3. Tension Between Custodial Finding and Platform's Business Model:

The Court found that WazirX held users' assets as custodian with fiduciary duties, but this finding somewhat contradicts the platform's operational structure. WazirX operated on a model where users could choose between P2P trading (facilitated by Binance) and non-P2P trading (operated by Zanmai Labs). The User Agreement explicitly stated that "the platform does not hold the virtual digital assets of its users in its capacity as a custodian or trustee".Rhutikumari_Vs_Zanmai_Labs.pdf​

While the Court properly looked beyond contractual disclaimers to the functional reality of the relationship, the tension remains. If cryptocurrency exchanges are deemed custodians with fiduciary duties as a matter of law (regardless of contractual terms), this has profound implications for the business models of all Indian exchanges. The judgment would have benefited from more explicit discussion of whether exchanges can contractually limit their custodial obligations or whether such obligations are imposed by law.

4. Limited Analysis of Force Majeure and Cyber Risk Allocation:

The User Agreement contained a force majeure clause covering cyberattacks. The Bombay High Court in Bitcipher Labs questioned whether force majeure could excuse not just service suspension but actual asset erosion, and the Madras High Court agreed with this reasoning. However, neither judgment fully developed the analysis of how cyber risk should be allocated between exchanges and users.Rhutikumari_Vs_Zanmai_Labs.pdf​

Cryptocurrency exchanges face unique security challenges. Despite implementing robust security measures—as WazirX claimed to have done with multi-signature wallets, hardware key storage, and address whitelisting—they remain vulnerable to sophisticated attacks by state-sponsored actors like the Lazarus Group. If exchanges bear unlimited liability for all losses regardless of security measures implemented, this could make exchange operation economically unfeasible or drive businesses offshore.fticybersecurity+1​

Conversely, if force majeure clauses allow exchanges to socialize all losses to users, this creates moral hazard and fails to incentivize security investment. The judgment would have benefited from deeper analysis of optimal cyber risk allocation in cryptocurrency custody relationships, potentially drawing on insurance law principles or examining regulatory approaches in other jurisdictions.

5. Insufficient Treatment of Cross-Border Complexity:

The judgment addresses jurisdictional issues but does not fully grapple with the cross-border complexity inherent in cryptocurrency disputes. WazirX involved an Indian company (Zanmai Labs), a Singaporean parent (Zettai), a briefly-involved international exchange (Binance), another Singaporean custodian (Liminal), a Singapore-based restructuring scheme, and Indian users accessing a global blockchain network.Rhutikumari_Vs_Zanmai_Labs.pdf​

The Court's finding that Indian courts have jurisdiction for interim relief is well-supported by PASL Wind Solutions, but the judgment does not address potential conflicts between orders from Indian and Singaporean courts. If the arbitral tribunal (seated in Singapore) reaches conclusions different from the Singapore High Court's approved scheme, which prevails? If Indian courts grant relief protecting specific users' assets, how does this interact with a Singapore court order binding all creditors to a collective scheme?

These questions of international comity and parallel proceedings deserve more extensive treatment, particularly given that similar cases are likely to arise as cryptocurrency becomes more prevalent.

6. Lack of Discussion on Practical Implementation:

The Court ordered Zanmai Labs to furnish a bank guarantee for ₹9,56,000 or deposit that sum in escrow. However, the judgment does not address practical challenges in implementing this order. Zanmai Labs claimed it did not control the cryptocurrency wallets—that Zettai and Liminal did. If this is accurate, how can Zanmai Labs provide meaningful security?Rhutikumari_Vs_Zanmai_Labs.pdf​

Moreover, the cryptocurrency's value fluctuates. The ₹9,56,000 figure represented the XRP coins' value as of one date, but XRP's price could rise or fall significantly during arbitration proceedings. Should the security amount be adjusted periodically? Should it be denominated in XRP rather than rupees?

These practical questions often determine whether judgments provide effective relief, and more attention to implementation mechanisms would strengthen the order's utility.

Unanswered Questions and Future Implications

1. Scope of Property Rights:

While the judgment establishes that cryptocurrency is property, it does not fully define the scope of property rights users possess. Do users own the specific cryptocurrency tokens they purchased, or merely a contractual right to equivalent value? This question becomes critical when exchanges commingle user assets or use pooled wallets rather than segregated accounts.

In traditional banking, depositors generally have contractual claims against the bank rather than property rights in specific currency notes. Does the same principle apply to cryptocurrency exchanges, or do users retain proprietary rights in the specific tokens they deposit? The judgment's language suggests the latter—referring to the applicant's XRP coins as her property held in trust—but more explicit analysis would clarify this crucial distinction.Rhutikumari_Vs_Zanmai_Labs.pdf​

2. Regulatory Implications:

The judgment will likely influence cryptocurrency regulation in India. By establishing that platforms hold assets as custodians with fiduciary duties, the Court has created a legal framework that may guide regulatory standards for exchange operations, security requirements, and consumer protection measures.

The Securities and Exchange Board of India (SEBI) or a new crypto regulator could build on this judgment to establish custody standards, segregation requirements, insurance obligations, and liability frameworks. The judgment provides judicial recognition of cryptocurrency's legitimacy as property, potentially encouraging more structured regulation rather than prohibition.

3. Taxation Consequences:

The recognition of cryptocurrency as property under general law complements but may also complicate its treatment as a "virtual digital asset" under tax law. Property classification could affect capital gains taxation, gift tax implications, inheritance tax treatment, and the application of wealth tax provisions (if reintroduced).Rhutikumari_Vs_Zanmai_Labs.pdf​

4. Insolvency and Bankruptcy:

The judgment's findings about property rights and trust relationships have significant implications for cryptocurrency insolvency scenarios. If exchange users have proprietary rights to their cryptocurrency (held in trust), these assets should not form part of the exchange's general estate in bankruptcy. Users would be entitled to return of their specific assets rather than merely ranking as unsecured creditors.

This conflicts with the Singapore restructuring approach, which treated users as creditors in a collective scheme. The tension between property-based and creditor-based approaches to exchange insolvency will need resolution in future cases.mudrex+1​Rhutikumari_Vs_Zanmai_Labs.pdf​

5. Criminal Law Implications:

Property classification affects criminal liability. If cryptocurrency is property, its theft, misappropriation, or criminal breach of trust can be prosecuted under the Indian Penal Code. The judgment strengthens the basis for criminal prosecution of cryptocurrency fraud, though challenges remain in investigating and prosecuting cross-border crypto crimes.

Review: Doctrinal Significance

Contribution to Property Law Jurisprudence

The judgment represents a significant evolution in Indian property law by extending established property concepts to novel digital assets. This evolutionary approach—using existing legal categories rather than creating entirely new frameworks—promotes legal stability while accommodating technological innovation.

The Court's methodology—examining property's essential characteristics rather than its physical form—reflects a mature approach to common law evolution. By focusing on whether cryptocurrency exhibits the "insignia or characteristic of proprietary right" (ownership, transferability, exchangeability, beneficial enjoyment), the Court avoided formalistic constraints while maintaining doctrinal coherence.Rhutikumari_Vs_Zanmai_Labs.pdf​

This approach aligns with Justice Holmes's famous observation that "the life of the law has not been logic; it has been experience." The Court recognized that as new forms of value emerge, property law must adapt to protect legitimate interests while maintaining core principles.

Relationship to Constitutional Rights

Although not extensively discussed in the judgment, property classification implicates constitutional protections. While the right to property is no longer a fundamental right in India (having been removed from Part III of the Constitution by the 44th Amendment in 1978), Article 300A provides that "no person shall be deprived of his property save by authority of law."

By establishing cryptocurrency as property, the judgment extends Article 300A's protection to digital assets. Government action affecting cryptocurrency ownership must therefore comply with Article 300A's requirements, including adequate legal authority and due process.

This constitutional dimension may prove significant if the government attempts to ban or confiscate cryptocurrency holdings. Any such action would need to overcome Article 300A scrutiny and potentially Article 19(1)(g) protections (right to practice any profession or trade), as recognized in Internet and Mobile Association of India v. RBI.Rhutikumari_Vs_Zanmai_Labs.pdf​

Trust Law Implications

The finding that exchanges hold cryptocurrency "in trust" invokes India's trust law framework. If this characterization is taken seriously, it suggests that:Rhutikumari_Vs_Zanmai_Labs.pdf​

1. Fiduciary Duties: Exchange operators owe fiduciary duties to users, including duties of loyalty, care, and good faith. These duties cannot be fully contracted away.

2. Segregation Requirements: Trust property should be segregated from the trustee's own assets. Commingling cryptocurrency in pooled wallets might violate this principle.

3. Prohibited Self-Dealing: Exchanges cannot use customer assets for their own benefit without explicit authorization.

4. Accounting Obligations: Trustees must maintain clear accounts of trust property. Exchanges should provide transparent, verifiable proof of reserves.

5. Insolvency Protection: Trust property should be returned to beneficiaries rather than distributed among general creditors in insolvency.

These trust law principles could fundamentally reshape cryptocurrency exchange regulation if consistently applied.

Precedential Value and Binding Effect

As a single-judge decision of a High Court, this judgment binds lower courts within the Madras High Court's jurisdiction but serves as persuasive authority for other High Courts and the Supreme Court. Given its comprehensive analysis, international precedent citation, and reliance on Supreme Court property law jurisprudence, the judgment is likely to be influential across India.

The judgment will be particularly persuasive because:

1. It addresses an issue of first impression in India with minimal direct precedent

2. It engages extensively with Supreme Court authority on property law

3. It demonstrates consistency with international trends across multiple common law jurisdictions

4. It provides practical application to a real-world dispute rather than abstract theorization

5. It balances innovation accommodation with rights protection

Unless contradicted by a Division Bench of the Madras High Court or the Supreme Court, this judgment will likely serve as the foundation for Indian cryptocurrency property jurisprudence.

Broader Implications for India's Cryptocurrency Ecosystem

Impact on Exchange Operations

The judgment significantly affects how cryptocurrency exchanges operate in India. Exchanges can no longer maintain that they merely facilitate peer-to-peer transactions without custodial responsibility—at least not when they actually control user assets through wallet infrastructure.Rhutikumari_Vs_Zanmai_Labs.pdf​

This finding will require exchanges to:

1. Implement Robust Security: Enhanced security measures become not merely good practice but legal obligations flowing from custodial duties.

2. Maintain Adequate Reserves: If holding assets in trust, exchanges must maintain sufficient reserves to cover all user balances, limiting ability to lend or invest customer assets.

3. Provide Transparent Accounting: Proof of reserves, regular audits, and transparent disclosure become essential to demonstrate compliance with custodial obligations.

4. Secure Insurance: Exchanges may need to obtain insurance coverage for cyber risks to ensure they can satisfy custodial obligations even after security breaches.

5. Revise User Agreements: Disclaimers of custodial responsibility may be ineffective if courts look to functional reality rather than contractual language.Rhutikumari_Vs_Zanmai_Labs.pdf​

These requirements increase operational costs but enhance user protection, potentially increasing trust in the cryptocurrency ecosystem.

Regulatory Landscape

The judgment arrives at a critical juncture for Indian cryptocurrency regulation. After the Supreme Court struck down the RBI's banking ban in 2020, India has pursued a balanced approach—imposing tax reporting requirements and anti-money laundering obligations without comprehensive prohibition.Rhutikumari_Vs_Zanmai_Labs.pdf​wikipedia​

The government's 2022 Budget introduced 30% taxation on virtual digital asset income and 1% TDS on transactions above thresholds, signaling acceptance of cryptocurrency's continued existence even while discouraging speculation. The judgment provides legal foundation for more structured regulation by:ndtv+2​

1. Clarifying Legal Status: Regulators can now build frameworks based on cryptocurrency's established property status rather than debating its fundamental nature.

2. Defining Custodial Standards: The finding of custodial and fiduciary duties provides basis for regulatory standards governing exchange operations.

3. Enabling Consumer Protection: Property rights recognition facilitates consumer protection mechanisms, dispute resolution, and remedies for fraud or misappropriation.

4. Supporting Financial Integration: Clear legal status may encourage traditional financial institutions to offer cryptocurrency-related services within defined regulatory parameters.

The judgment may accelerate development of comprehensive cryptocurrency legislation, potentially including licensing requirements for exchanges, mandatory security standards, consumer protection mechanisms, and clear tax treatment.

Impact on Innovation and Investment

Legal clarity generally promotes innovation and investment by reducing regulatory risk. The judgment's recognition of cryptocurrency as property provides several benefits for India's Web3 ecosystem:

Positive Impacts:

1. Legitimacy: Judicial recognition that cryptocurrency is property rather than mere "digital data" or "speculative instruments" provides legitimacy that encourages mainstream adoption.

2. Investment Security: Clear property rights make investors more confident that their holdings are legally recognized and protected.

3. Contractual Clarity: The ability to treat cryptocurrency as property in contracts, collateral arrangements, and business transactions facilitates commercial innovation.

4. Startup Formation: Legal clarity around cryptocurrency enables startups to build compliant businesses without fear of fundamental legal challenge to their asset base.

Potential Concerns:

1. Regulatory Burden: If exchanges face extensive custodial obligations and potential liability for cyber losses, smaller exchanges may exit the market, reducing competition.

2. Offshore Migration: Heavy compliance requirements might drive cryptocurrency businesses to more lenient jurisdictions, depriving India of economic benefits and tax revenue.

3. Innovation Constraint: Strict custodial standards might inhibit experimentation with new exchange models, decentralized finance protocols, or non-custodial platforms.

Optimal regulation would balance user protection with innovation support, potentially using tiered regulatory frameworks that impose requirements proportionate to exchange size and user risk exposure.

Global Context and India's Positioning

The judgment positions India within the emerging global consensus that cryptocurrency represents a legitimate form of property deserving legal protection. This aligns India with major common law jurisdictions (UK, Singapore, Australia, New Zealand) that have adopted similar approaches, while contrasting with more restrictive regimes (China's complete ban) or more permissive frameworks (El Salvador's adoption of Bitcoin as legal tender).Rhutikumari_Vs_Zanmai_Labs.pdf​ndtv+3​

India's balanced approach—recognizing cryptocurrency as property while maintaining regulatory oversight and taxation—may prove influential for other developing economies navigating cryptocurrency regulation. With over 100 million cryptocurrency users, India represents one of the world's largest crypto markets despite recent regulatory uncertainties.mudrex​

The judgment also impacts India's positioning in the global Web3 economy. With a large technology workforce, strong startup ecosystem, and growing blockchain industry, India has potential to become a Web3 leader. Legal clarity provided by this judgment supports that positioning by:

1. Enabling Indian cryptocurrency businesses to compete globally from secure legal foundation

2. Attracting international cryptocurrency investment to India

3. Supporting India's participation in global blockchain innovation

4. Providing legal framework for Indian institutions to engage with cryptocurrency

Recommendations and Future Directions

For Policymakers and Regulators

1. Comprehensive Cryptocurrency Legislation:

India should enact comprehensive cryptocurrency legislation building on this judgment's foundations. Such legislation should address:

• Clear definitions of cryptocurrency types and categories

• Licensing requirements for exchanges and custodians

• Security and risk management standards

• Consumer protection mechanisms and dispute resolution

• Tax treatment across various use cases

• Anti-money laundering and counter-terrorism financing requirements

• Integration with existing financial regulation

• Innovation support mechanisms (regulatory sandboxes, pilot programs)

2. Exchange Regulation Framework:

Based on the judgment's custodial findings, regulators should establish:

• Mandatory registration and licensing for cryptocurrency exchanges

• Capital requirements proportionate to asset under custody

• Security standards including cold storage, multi-signature controls, and insurance

• Proof of reserves requirements with regular third-party audits

• Segregation of customer assets from company assets

• Cyber incident response and user notification protocols

• Governance standards for exchange operations

3. Consumer Protection Mechanisms:

The judgment highlights vulnerability of individual users facing exchange insolvency or cyberattacks. Regulators should consider:

• Mandatory insurance or reserve funds to cover cyber losses

• Investor education programs about cryptocurrency risks

• Clear disclosure requirements about security measures, insurance coverage, and risk exposure

• Dispute resolution mechanisms including specialized tribunals or arbitration frameworks

• Compensation schemes similar to deposit insurance for catastrophic failures

For Cryptocurrency Exchanges

1. Operational Adjustments:

Exchanges should respond to the judgment by:

• Reviewing and strengthening custodial arrangements to ensure clear segregation of assets

• Implementing enhanced security protocols including regular penetration testing, bug bounties, and incident response plans

• Obtaining comprehensive insurance coverage for cyber risks and custodial liabilities

• Providing transparent proof of reserves with regular third-party audits

• Clearly documenting asset custody and control to distinguish company assets from customer holdings

2. Contractual Revisions:

User agreements should be revised to:

• Accurately reflect custodial relationships rather than disclaiming them

• Clearly explain cyber risk allocation and security measures

• Specify insurance coverage and user protections

• Define force majeure scope and remedies

• Establish arbitration procedures for disputes

• Ensure compliance with consumer protection laws

3. Technological Solutions:

Exchanges should explore technological approaches to risk management:

• Moving toward non-custodial or self-custodial models where feasible

• Implementing layer-two security solutions and decentralized custody protocols

• Using hardware security modules and multi-party computation for key management

• Maintaining higher percentages of assets in cold storage

• Deploying on-chain monitoring and anomaly detection systems

For Users and Investors

1. Due Diligence:

Cryptocurrency users should:

• Research exchange security practices, insurance coverage, and regulatory compliance

• Understand custody arrangements and where assets are actually held

• Review proof of reserves reports and third-party audits

• Consider diversifying across multiple exchanges to reduce concentration risk

• Evaluate non-custodial wallet options for long-term holdings

2. Legal Awareness:

Users should understand their legal rights, including:

• Property rights in cryptocurrency holdings

• Contractual obligations under user agreements

• Dispute resolution mechanisms available

• Tax reporting and compliance requirements

• Remedies available for exchange failure or misconduct

3. Risk Management:

Prudent risk management includes:

• Maintaining only necessary amounts on exchanges for active trading

• Using self-custodial wallets for long-term storage

• Implementing personal security measures (two-factor authentication, secure passwords, hardware wallets)

• Understanding and accepting risks inherent in cryptocurrency investment

• Avoiding concentration in single cryptocurrencies or platforms

For Legal Practitioners

1. Practice Development:

The judgment opens significant practice opportunities in:

• Cryptocurrency transaction documentation and structuring

• Exchange licensing and regulatory compliance advice

• Dispute resolution and arbitration in cryptocurrency cases

• Tax planning and compliance for virtual digital assets

• Insolvency and restructuring involving cryptocurrency

• Criminal defense and prosecution in crypto fraud cases

2. Doctrinal Development:

Legal scholars and practitioners should engage with emerging questions:

• Scope of property rights in fungible versus non-fungible tokens

• Application of trust law principles to various cryptocurrency custody models

• Cross-border enforcement of cryptocurrency property rights

• Intersection of cryptocurrency with other legal areas (securities law, contract law, criminal law)

• Comparative analysis of cryptocurrency regulation across jurisdictions

Conclusion: A Landmark with Lasting Impact

The Madras High Court's judgment in Rhutikumari v. Zanmai Labs represents a watershed moment in Indian cryptocurrency jurisprudence. By comprehensively analyzing cryptocurrency as property, establishing custodial obligations for exchanges, and providing interim protection for individual property rights, Justice Venkatesh has laid a strong foundation for India's evolving legal framework for digital assets.

The judgment's strengths are substantial: comprehensive analysis of technological and legal dimensions, integration of international precedents, application of established property law principles to novel circumstances, and careful balance between innovation support and rights protection. These qualities suggest the judgment will serve as a leading authority in Indian cryptocurrency law for years to come.

However, the judgment also leaves important questions unresolved and faces practical implementation challenges. The tension between individual property rights and collective insolvency schemes, optimal allocation of cyber risks, appropriate regulatory frameworks, and cross-border enforcement mechanisms all require further doctrinal and regulatory development.

Most fundamentally, the judgment reflects a judicial philosophy that accommodates technological innovation within established legal frameworks rather than resisting it or creating entirely novel legal categories. This approach—extending "property" to encompass cryptocurrency by examining its essential characteristics rather than its physical form—demonstrates common law's adaptive capacity and suggests that India's legal system can evolve to address the challenges and opportunities of the Web3 era.

For Rhutikumari and millions of other Indian cryptocurrency users, the judgment provides reassurance that their digital holdings are not merely speculative bets in an unregulated space but legitimate property interests deserving legal protection. For exchanges, the judgment clarifies custodial obligations and encourages security investment. For regulators, it provides foundation for structured regulation. For India's Web3 ecosystem, it offers legal clarity that can support continued innovation and growth.

The immediate impact protects an individual investor's XRP holdings from dilution due to losses she did not suffer. The lasting legacy establishes that in India's legal system, cryptocurrency is property—capable of being owned, enjoyed, transferred, and held in trust—deserving of the full panoply of legal protections that status entails. As India continues to navigate its relationship with cryptocurrency and blockchain technology, this judgment will serve as a crucial reference point, balancing legitimate regulatory concerns with the fundamental property rights that underpin economic liberty and innovation.

The global cryptocurrency ecosystem continues to evolve rapidly, facing challenges including cyber security threats, regulatory uncertainty, market volatility, and technological change. Within this dynamic environment, clear legal principles provide stability and confidence essential for sustainable development. By establishing such principles for India's massive and growing cryptocurrency user base, the Madras High Court has made a significant contribution not only to Indian jurisprudence but to global efforts to integrate cryptocurrency within established legal frameworks while preserving innovation, individual rights, and financial inclusion.

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