Tuesday, 7 March 2023

Can the court release seized property at the investigation stage U/S 457 of CRPC even if not produced before the court?

 The fact that the Hon’ble Supreme Court has given a direction to the learned Criminal Court to consider release of seized property/articles at the investigation stage under Section 457 Cr.P.C, shows that Section 457 Cr.P.C. can be applied by the Criminal Court at the investigation stage for release of seized

property.The submission made by the counsel for the appellant that the judgment of the Apex Court in Ram Prakash Sharma (supra) did not deliberate on the scope of Section 457 Cr.P.C, for granting custody of seized property at the stage of investigation cannot be accepted by us. While different situations and circumstances could arise in respect of seized property, one situation that can arise is when the police submit a final negative report and the police authorities fail to release custody of the seized property in terms of

Section 102 Cr.P.C. In that case, there would be no remedy for the aggrieved person, except to approach the High Court under Section 482 Cr.P.C or Article 226 of the Constitution, which would be a difficult task for people living in far flung areas and those belonging to the weaker sections of society. In that event,

Section 457 Cr.P.C would become redundant. After considering the decisions of the Apex Court and the various High Courts alongwith Section 457 Cr.P.C, we are of the considered opinion that the words “and such property is not produced before a Criminal Court during an inquiry or trial”, appearing in sub-Section (1) of Section 457 Cr.P.C, cannot be restricted to mean that the stage of inquiry or trial is a condition precedent, for a Court to have jurisdiction for exercising power under Section 457 Cr.P.C. at the investigation stage. We are of the view that the words “and such property is not produced before a Criminal Court during the inquiry or trial” appearing in Section 457(1) Cr.P.C would have to be considered to be a reference to a stage of investigation and not the stage of inquiry or trial. Further, we are bound by the decision of the Apex Court in Ram Prakash Sharma (supra) , in terms of Article 141 of the Constitution of India, as it is the mandate of the Constitution that the law declared by the Supreme Court shall be binding on all Courts within the territory of India. Also, in the case of Anil Kumar Neotia vs. Union of India & Others, reported in AIR 1988

SC 1353, it has been held that the High Court cannot question the correctness of the decision of the Supreme Court, even though the points stated before the High Court were not considered by the Supreme Court. {Para 44}

45. In view of the reasons stated above, we answer the reference by holding that at the investigation stage, seized articles cannot be released by a Court under Section 451 Cr.P.C. However, under Section 457 Cr.P.C., the Criminal Court has the jurisdiction to give custody of seized property/articles at the stage of investigation, when those seized property are not produced before the Court.

THE GAUHATI HIGH COURT

(HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH)

Crl.Pet 284/2022

The State of Assam and Another.  Vs Ram Sankar Maurya. 

BEFORE

HON’BLE MR. JUSTICE MICHAEL ZOTHANKHUMA

HON’BLE MRS. JUSTICE MALASRI NANDI

Author: (M. Zothankhuma, J)

Date of judgment : 02.03.2023

Heard Mr. P.N. Goswami, learned Additional Advocate General for the

State. Also heard Mr. Z. Kamar, learned Senior Counsel assisted by Mr. N.H.Barbhuiya, learned counsel for the respondent in Crl. Pet. No. 505/2022 and Cr.

Pet. No. 517/2022; Mr. P.J. Saikia, learned Senior Counsel assisted by Mr. A.K.

Gupta, learned counsel for the respondent in Crl. Pet. No. 356/2022 and Crl.

Pet. No. 358/2022; Mr. M. Biswas, learned counsel for the respondent in Crl.

Pet. No. 284/2022; Mr. A. Sarma, learned counsel for the respondent in Crl. Pet.

No. 641/2022 and Mr. A. Duarah, learned counsel for the respondent in Crl. Pet.

No. 642/2022.

2. This batch of petitions has been referred to by a Single Bench of this Court

to decide the question “whether pending investigation, seized articles can be

released by the Court, by exercising the jurisdiction, either under Section 451,

or under Section 457 of the Cr.P.C.”

3. Mr. P N Goswami, learned Addl. Advocate General submits that a Court

cannot release seized articles under Section 451, 457 or 102 Cr.P.C during the

stage of investigation, unless and until the case reaches the stage of enquiry or

trial. He also submits that Section 102 Cr.P.C provides power to the Police

Officer, to give custody of any seized property to any person and the said

provision does not give any power to the Court to give custody of such property

to any person during the investigation stage.

4. The learned Addl. Advocate General submits that the orders passed by this

Court in the case of; (1) The State of Assam & Anr. vs. Nur Uddin Daskar,

Crl. Pet. No. 368/2022. (2) The State of Assam & Anr. vs. Lalhruaizela,

Crl. Pet. No. 597/2022 (3.) Rafikul Islam vs. State of Assam, Crl. Rev.

Pet. No. 16/2022 have clearly held that the definition of the words “Inquiry”

provided under Section 2(g) Cr.P.C and the definition of “Investigation” as

provided under Section 2(h) Cr.P.C shows that an inquiry is not an investigation.

Further, as “trial” does not encompass investigation, the power to release seized

property under Section 451 Cr.P.C cannot be exercised by a criminal Court at the

time of investigation.

5. The learned Addl. Advocate General has also submitted that though the

wording of Section 451 Cr.P.C and 457 Cr.P.C are similar, the difference is that

the seized property is produced before the criminal Court during an inquiry or

trial under Section 451 Cr.P.C, while there is no production of the seized

property before a criminal Court during an enquiry or trial under Section 457

Cr.P.C, though the seizure of the property by the Police during investigation is

reported to the Magistrate under Section 457 Cr.P.C. He submits that as the

criminal Court does not have the power to release custody of property under

Section 451 Cr.P.C unless the case reaches the stage of inquiry or trial, the same

yardstick would apply to release of seized property under Section 457 Cr.P.C.

He submits that in the case of Nevada Properties Pvt. Ltd. vs. State of

Maharashtra & Anr ., (2019) 20 SCC 119, the Supreme Court has held that

while Section 451 Cr.P.C empowers the criminal Court to pass an order of

custody of any property during an inquiry or trial, Section 457 Cr.P.C applies to

properties which have been seized by the police officer during investigation, but

not produced during inquiry or trial.

He also submits that the learned Single Judge of this Court in the case of

Sunil Gogoi vs. State of Assam, reported in 2002 (3) GLR 572, fell into


error when it held that Section 457 Cr.P.C. gets attracted when trial has not yet

started. He submits that in terms of the judgment of the learned Single Judge in

Sunil Gogoi (supra), the Court can give custody or dispose of seized property

even at the investigation stage, which is not in consonance with the provisions

of Section 457 Cr.P.C.

The learned Additional Advocate General has also taken us through various

provisions of the Cr.P.C, with regard to the definition of inquiry, investigation and

Chapter-XXXIV Cr.P.C, in support of his stand that the power of the Court to give

custody of a seized property under Section 451 and 457 Cr.P.C. during the

investigation stage comes into play, only after a case reaches the stage of

enquiry or trial.

6. The learned Additional Advocate General also submits that as per the

Cr.P.C., 1973, custody of seized property can be given during investigation under

Section 102 Cr.P.C. only by a police officer. However, there is no provision for

giving custody of the seized property/article at the stage of investigation by the

Court under Sections 102, 451 or 457 Cr.P.C. He also submits that in terms of

Section 523 of the old Criminal Procedure Code, 1898, which corresponds to the

present Section 457 Cr.P.C., the Court was empowered to dispose or give

custody of any seized property at the time of investigation, inquiry or trial.

However, in the Cr.P.C., 1973, the power of the Court to give custody of a seized

property under Section 457 Cr.P.C during the stage of investigation has been

taken away, till such time the case reaches the stage of inquiry or trial. He

submits that if the intention of the legislature was to give power to the Court to

give custody of seized property during investigation, the same could have been

easily stated in clear terms in Section 457 Cr.P.C The same not being done, the

Court has no power to give custody of seized property during investigation. In

support of his submissions, the learned Additional Advocate General has relied

upon various judgments, which are as follows :

(i) Nevada Properties Private Limited, through its Directors vs.

State of Maharashtra & Another , reported in (2019) 20 SCC 119.

(ii) Hardeep Singh vs. State of Punjab & Others, reported in

(2014) 3 SCC 92

(iii) Directorate of Revenue Intelligence vs. PRK Diamonds Pvt.

Ltd., (2019) SCC Online Del 822 and

(iv) Directorate of Revenue Intelligence, Shillong Regional Unit,

Shillong vs. Shri. Ajay Babu Manda, Crl. Pet. No. 1/2022.

(v) Noorkhan Jafarkhan vs. SK Kakeer Sk Akbar and Balaji vs.

State of Andhra Pradesh, reported in 2003 0 AIIMR (Crl.) 878

(vi) Balaji vs. State of Andhra Pradesh, reported in 1976 0 CrLJ

1461.

7. The learned Additional Advocate General has also submitted various

judgments of the Apex Court with regard to principles to be followed while

interpreting Statutes, which are as follows :

(i) Visitor, AMU & Others vs. K.S. Misra, reported in (2007) 8 SCC

593,

(ii) Nathi Devi vs. Radha Devi Gupta, reported in (2005) 2 SCC

271,

(iii) Commissioner of Wealth Tax vs. Dr. Karan Singh & Others,

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reported in 1993 Supp (4) SCC 500

8. The learned counsels for the respondents, on the other hand, submit that

custody of the seized property can be given by a Criminal Court under Section

451 Cr.P.C and Section 457 Cr.P.C, during the investigation stage also. In this

regard, they have relied upon the judgments of the Supreme Court in the case

of Sunderbhai Ambalal Desai & Ors. vs. State of Gujarat , reported in

(2002) 10 SCC 283 and in the case of Multani Hanif bhai Kalubhai vs.

State of Gujarat & Ors ., reported in (2013) 3 SCC 240. They submit that

though the Supreme Court has not stated in so many words that the Court can

give custody of seized property during the stage of investigation, the facts

enumerated in the above two cases and the directions issued therein, implies

that Section 451 Cr.P.C is applicable, for releasing custody of seized property

during the stage of investigation.

9. The respondents’ counsels submit that in terms of Section 102 Cr.P.C,

Police can give custody of seized property during investigation. However,

problems would arise if the Police fail to give custody of seized property under

Section 102 Cr.P.C. In that eventuality, where would citizens go for getting

custody of the same, keeping in view the fact that sometimes, investigation

goes on for years together.

10. The respondents’ counsels also submit that the Division Bench of this

Court in W.A No. 296/2019, “Ali Trading & Anr. vs. State of Assam & 6

Ors., had held that any seizure affected by invoking Section 102(1) Cr.P.C would

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have to be subjected to the procedure prescribed under Section 102(3), i.e. to

forthwith submit a report of the seizure to the Magistrate. Without such

procedure being undertaken, any detention of the seized article would have to

be said to be without authority and jurisdiction and Courts would have to step in

to release the seized property. However, in the event of seizures being followed

up with submission of reports to the Magistrate, it would be subject to the

procedure provided under Section 451 Cr.P.C.

11. The respondents’ counsels also submit that in the case of Ram Parkash

Sharma vs. State of Haryana, reported in (1978) 2 SCC 491, the Apex Court

has held that Section 457 Cr.P.C can be applied by the Court for releasing

custody of the seized property when the investigation is not over and chargesheet

has not yet been filed.

12. The respondents’ counsels also submit that the Division Bench of Calcutta

High Court in the case of Ambika Roy vs. The State of Calcutta, reported in

(1974) 0 Cr.LJ 1002, had on interpreting Section 457 Cr.P.C., held that the

words “such property is not produced before a Criminal Court during an inquiry

or trial” appearing in Section 457 Cr.P.C, merely referred to the stage of

investigation and not the stage of inquiry or trial. As such, it had held that a

Court had the power to give custody of seized property at the stage of

investigation under Section 457 Cr.P.C.

13. The learned counsels for the respondents thus submit that custody of

seized property can be given by Courts during the investigation stage under

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Section 451 and 457 Cr.P.C. In support of their submissions, they have relied

upon various judgments of various High Courts which are as follows :

(i) Ghafoor Bhai Nabbu Bhai Tawar vs. Motiram Keshaorao

Bongirwar & Ors., reported in (1977) 0 Supreme (Bom) 77,

(ii) M.S Jaggi vs. Subashchandra Mohapatra, reported in (1997) 0

Supreme (Ori) 28,

(iii) Ajai Singh vs. Nathi Lal & Others , reported in 1978 CRI L.J.

629,

(iv) Bharat Heavy Electricals Ltd., Hyderabad vs. State &

Another, reported in 1981 CRI. L.J. 1529

(v) Joshy vs. The State, reported in 1986 CRI. L.J. 263

(vi) Dheerendra Dwivedi @ Dheeru vs. State of M.P. (Criminal

Revision No.2078/2020),

14. The learned counsels for the respondents also submit that in case of

ambiguity, in the construction of a penal statute, the Court must favour the

interpretation which leans towards protecting the rights of the accused, given

the ubiquitous power disparity between the individual accused and the State

machinery, as laid down by the Apex Court in the case of M. Ravindran vs.

Directorate of Revenue Intelligence, reported in (2021) 2 SCC 485.

15. The learned Advocate General submits that the stand taken by the

respondents’ counsels that seized property can be given in custody by the

Courts during the investigation stage under Section 457 Cr.P.C., by relying upon

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two Apex Court decisions i.e. Sunderbhai Ambala Desai vs. State of

Gujrat, reported in (2002) 10 SCC 283 and in the case of Ram Prakash

Sharma vs. State of Haryana, reported in (1978) 2 SCC 491, is misplaced.

He submits that the Apex Court’s direction in Sunderbhai Ambala Desai

(supra) to the concerned Magistrate, to take immediate action under Section

451 Cr.P.C for releasing the seized property, so as to ensure that the same was

not kept at the police station for not more than 15 (fifteen) days to 1 (one)

month, was made at the stage of trial. He submits that there was no issue

framed or adjudicated by the Apex Courts on the scope of grant of custody by a

Criminal Court under Section 451 and Section 457 Cr.P.C during the stage of

investigation. Further, the decision taken in the above case was only with

respect to Section 451 Cr.P.C. and not Section 457 Cr.P.C.

16. The learned Advocate General submits that the direction passed by the

Apex Court in Ram Parkash Sharma (supra) to release seized property

under Section 457 Cr.P.C. during the investigation stage cannot be a law holding

the field, as there was no deliberations made by the Apex Court, on the scope

of grant of custody of seized property during the stage of investigation under

Section 457 Cr.P.C. He submits that the decision made by the Apex Court in

Ram Parkash Sharma (supra) was not accompanied by reasons and

accordingly the same could not be deemed to be a law declared to have a

binding effect, as contemplated by Article 141 of the Constitution.

17. We have heard the learned counsels for the parties.

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18. For adjudicating the issue at hand, the definition of the words inquiry and

investigation as provided in Section 2(h) to 2(g) are reproduced below :

As per Sec. 2 ( h ) of Cr. P.C., Investigation has been defined in the following

terms :

(h) “Investigation” includes all the proceedings under this Code for the

collection of evidence conducted by a police officer or by any person (other than

a Magistrate) who is authorized by a Magistrate in this behalf.

While under S. 2(g) of Cr.P.C ‘Inquiry’ is defined as:

”Inquiry” means every inquiry, other than a trial, conducted under this Code by

a Magistrate Court.

19. What is investigation ?

The Code of Criminal Procedure provides the procedure for investigation and the

report of the Police Officer on completion of investigation.

Sec. 157 Cr.P.C states as follows:-

“157. If, from information received or otherwise, officer in charge of a police

station has reason to suspect the commission of an offence which he is

empowered under section 156 to investigate, he shall forthwith send a report of

the same to a Magistrate empowered to take cognizance of such offence upon a

police report and shall proceed in person, or shall depute one of his subordinate

officers not being below such rank as the State Government may, by general or

special order, prescribe in this behalf, to proceed, to the spot, to investigate the

facts and circumstances of the case, and, if necessary, to take measures for the

discovery and arrest of the offender;”

Sec 173 (1) of Cr.P.C adumbrates that the Investigation shall be completed

without unnecessary delay.

20. The Apex Court while considering the case of H. N. Rishbud And Inder

Singh Vs. The State Of Delhi , reported in 1955 AIR SC 196, State of U.P

vs. Bhagwant Kishore Joshi, 1964 3 SCR 71 and Satish Narayan

Sawant vs. State of Goa, 2012 8 SCC 365 held that investigation consists

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generally of the following steps:

1. Proceeding to the spot,

2. Ascertainment of the facts and circumstances of the case,

3. Discovery and arrest of the suspected offender, and

4. Collection of evidence relating to the commission of the offence which may

consist of (a) the examination of various persons (including the accused) and

the reduction of their statements into writing, if the officer thinks fit, (b) the

search of places of seizure of things considered necessary for the investigation

and to be produced at the trial, and

5. Formation of the opinion as to whether on the material collected there is a

case to place the accused before a Magistrate for trial and if so taking the

necessary steps for the same by the filing of a charge-sheet under section 173.

21. In the case of Hardeep Singh (supra), the Apex Court has held that the

stage of inquiry commences, insofar as the court is concerned, with the filing of

the charge-sheet and the consideration of the material collected by the

prosecution, that is mentioned in the charge-sheet for the purpose of trying the

accused. This has to be understood in terms of Section 2(g) CrPC, which defines

an inquiry as

every inquiry, other than a trial, conducted under this Code by a Magistrate or

court.

22. In the case of Niranjan Singh Vs. State of U.P., reported in AIR 1957

SC 142, it has been laid down by the Apex Court that investigation is certainly

not an inquiry or trial before the Court and that is why the Legislature did not

contemplate any irregularity in investigation as of sufficient importance to vitiate

or otherwise form any infirmity in the inquiry or trial. In Manubhai Ratilal

Patel Vs. State of Gujarat and Others, reported in (2013) 1 SCC 314, the

Apex court held as “It is apposite to note that the investigation, as has been

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dealt with in various authorities of this Court, is neither an inquiry nor trial.”

23. In view of the judgments of the Apex Court enumerated in the foregoing

paragraphs, it is clear that investigation is an activity which is different from an

inquiry or trial. As the stage of inquiry commences from the date of filing of the

charge-sheet, the period prior to filing of the charge-sheet would have to be

considered to be the stage of investigation.

24. Now coming to the question as to whether a Criminal Court can release

custody of seized property during investigation under Section 451 or 457 Cr.P.C,

we would have to see the provisions of Section 102, 451 to 457 Cr.P.C and the

judgments passed by the Supreme Court and various High Courts.

Section 102, 451 and 457 Cr.P.C are reproduced below as follows:-

“102. Power of police officer to seize certain property: -

1. Any police officer may seize any property which may be alleged or

suspected to have been stolen, or which may be found under

circumstances which create suspicion of the Commission of any offence.

2. Such police officer, if subordinate to the officer in charge of a police

station, shall forthwith report the seizure to that officer.

3. Every police officer acting under Sub-Section (1) shall forthwith

report the seizure to the Magistrate having jurisdiction and where the

property seized is such that it cannot be, conveniently transported to the

Court or where there is difficulty in securing proper accommodation for

the custody of such property, or where the continued retention of the

property in police custody may not be considered necessary for the

purpose of investigation, he may give custody thereof to any person on

his executing a bond undertaking to produce the property before the

Court as and when required and to give effect to the further orders of the

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Court as to the disposal of the same.

Provided that where the property seized under Sub-Section (1) is subject

to speedy and natural decay and if the person entitled to the possession

of such property is unknown or absent and the value of such property is

less than five hundred rupees, it may forthwith be sold by auction under

the orders of the Superintendent of Police and the provisions of sections

457 and 458 shall, as nearly as may be practicable, apply to the net

proceed of such sale.

“451. Order for custody and disposal of property pending trial in

certain cases. When any property is produced before any Criminal Court

during any inquiry or trial, the Court may make such order as it thinks fit

for the proper custody of such property pending the conclusion of the

inquiry or trial, and, if the property is subject to speedy and natural decay,

or if it is otherwise expedient so to do, the Court may, after recording

such evidence as it thinks necessary, order it to be sold or otherwise

disposed of.

Explanation.- For the purposes of this section," property" includes-

(a) property of any kind or document which is produced before the

Court or which is in its custody,

(b) any property regarding which an offence appears to have been

committed or which appears to have been used for the commission

of any offence.”

“457.Procedure by police upon seizure of property.-(1) Whenever

the seizure of property by any police officer is reported to a Magistrate

under the provisions of this Code, and such property is not produced

before a Criminal Court during an inquiry or trial, the Magistrate may

make such order as he thinks fit respecting the disposal of such property

or the delivery of such property to the person entitled to the possession

thereof, or if such person cannot be ascertained, respecting the custody

and production of such property.

(2) If the person so entitled is known, the Magistrate may order the

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property to be delivered to him on such conditions (if any) as the

Magistrate thinks fit and if such person is unknown, the Magistrate may

detain it and shall, in such case, issue a proclamation specifying the

articles of which such property consists, and requiring any person who

may have a claim thereto, to appear before him and establish his claim

within six months from the date of such proclamation.”

25. On reading the various judgments enumerated in the foregoing paragraph

and the provisions of Chapter XXXIV of the Code of Criminal Procedure, we are

of the view that the Court can make an order for the proper custody of the

seized property under Section 451 Cr.P.C only after a charge-sheet is filed.

Section 452 Cr.P.C is to be applied for disposal of property, only at the

conclusion of an inquiry or trial. Section 459 Cr.P.C, on the other hand, allows

for the Court to sell the seized property, if the person entitled to possession of

the property is unknown or absent and the property is subject to speedy and

natural decay or that the sale would be for benefit of the owner or the value of

the property is less than Rs. 500/-.

26. In the case of Directorate of Revenue Intelligence vs. PRK

Diamonds Pvt. Ltd., (2019) SCC Online Del 822 , the Delhi High Court held

that for the applicability of Section 451 Cr.P.C, an enquiry or trial has essentially

to be in progress.

27. In the case of Directorate of Revenue Intelligence, Shillong

Regional Unit, Shillong vs. Shri. Ajay Babu Manda, Crl. Pet. No.

1/2022, the Meghalaya High Court held that in the absence of a trial or inquiry

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under Section 451/457 Cr.P.C, the Magistrate could not have released the seized

vehicles to the owners of the vehicles.

28. in the case of The State of Assam & Anr. vs. Nur Uddin Daskar, Crl.

Pet. No. 368/2022. (2) The State of Assam & Anr. vs. Lalhruaizela, Crl.

Pet. No. 597/2022 (3.) Rafikul Islam vs. State of Assam, Crl. Rev. Pet.

No. 16/2022, the Ld. Single Judges of this Court have held that during the

investigation stage, the power to give custody of a seized property under

Section 451 Cr.P.C. could not be exercised by Criminal Courts. Nothing was

stated in the above three decisions with regard to whether the Criminal Court

could give custody of a seized property during the investigation stage under

Section 457 Cr.P.C. However, in the case of Sunil Gogoi (supra), another

Single Bench of this Court had held that the Criminal Court has the power to

pass an order of interim custody to the rightful owner, either under Section 451

Cr.P.C. pending trial of the case or under Section 457 Cr.P.C. when the property

is seized by the police and trial has not yet started. Thus a reading of the

judgment in Sunil Gogoi (supra), implies that a Criminal Court can give

custody of a seized property under Section 457, prior to the start of trial, i.e. at

the inquiry stage and investigation stage.

29. In the case of Ghafoor Bhai Nabbu Bhai Tawar (supra) the Bombay

High Court has held that the provision of Section 457 Cr.P.C. are sufficiently wide

so as to cover a case where the Magistrate is called upon to pass an order for

disposal or custody of a property during the investigation stage.

In the case of M.S Jaggi (supra), the Orissa High Court has held that the

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Expression, “and such property is not produced before a Criminal Court during

an inquiry or trial” appearing in Section 457(1) merely refers to a stage of

investigation and provide a condition precedent for exercise of jurisdiction of the

Magistrate under the Section.

30. In the case of Ajai Singh (supra), the Division Bench of the Allahabad

High Court has held that a Magistrate may have to exercise jurisdiction under

Section 457 Cr.P.C in different situations and circumstances. A person whose

property has been seized may apply to the Magistrate for its release while the

investigation is still in progress and before commencement of an inquiry or trial

and before an occasion to produce the seized property before a Criminal Court

arises.

The Allahabad High Court then held that it found nothing in the language of

Section 457 Cr.P.C to restrict its application and take away the jurisdiction of the

Magistrate until trial or inquiry is held and the property is actually not produced

in the court or during the investigation of the case.

31. In the case of Nevada Properties Private Limited vs. State of

Maharashtra & Ors ., reported in 2019 20 SCC 119, the issue that was to be

decided by the Apex Court was whether the expression “any property” used in

sub-section (1) of Section 102 Cr.P.C would include immovable property and,

consequently, whether a police officer investigating a criminal case couild take

custody of and seize any immovable property, which may be found under

circumstances which create suspicion of the commission of any offence.

The Apex Court, on considering the above issue in conjunction with Chapter

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XXXIV of the Code of Criminal Procedure, which relates to disposal of property

under Section 451 to 459, held that Section 451, 452 & 456 does not refer to

any seized property under Section 102 Cr.P.C. It held that the power of the

Criminal Court under Section 451, 452 & 456 is not restricted to property seized

by the police officer under Section 102 of the Code, i.e. it had the jurisdiction to

give orders pertaining to immoveable property also. However, Section 457 Cr.P.C

applied to properties which had been seized by the police officer under Section

102 of the Code, but not produced during inquiry or trial. The Apex Court

thereafter held that the power of the criminal court under Section 451, 452 and

456 of the Code was not restricted to property seized by the police officer under

Section 102 of the Code. However, Section 457 Cr.P.C, applied to properties

which have been seized by the police officer under the Code but not produced

during inquiry or trial. It thus held that the Expression “any property” appearing

in Section 102 of the Code would not include immovable property.

32. The Judgment of the Apex Court in Nevada Properties Private Limited

(supra) was not with regard to the issue that has to be decided herein and

neither was the same considered. The Apex Court held that the expression “any

property” in Section 102 Cr.P.C would cover only moveable property. The Apex

Court has referred to Section 457 Cr.P.C only in the last five lines of paragraph

26 in the entire judgment, which as follows :

“26. We have referred to the said provisions under Chapter XXXIV

–‘Disposal of Property’, as this would be of significance and, addresses the

argument and concern expressed by the appellant – Nevada Properties

Pvt. Ltd. and some of the State Governments. These provisions,

specifically enable the Court to pass orders relating to the properties, both

movable and immoveable. We have referred to Section 451, which does

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not specifically refer to any seizure order under Section 102 of the Code

but vide Explanation includes such property regarding which an offence

appears to have been committed or which appears to have been used for

the commission of any offence. Similarly, Section 452 refers to property

regarding which an offence appears to have been committed as has been

originally in possession or under control of any party and also such

property into or for which the same may have been converted or

exchanged. Again Section 452 per se, does not make any reference to

Section 102 of the Code. This is also true for Section 456 of the Code

which relates to restoration of possession of immovable property in certain

circumstances. These provisions, therefore, do not directly define the

contours and scope of Section 102 of the Code. On the other hand, it

would show that Section 102 is not the primary or the core provision

which would make the provisions of Section 451, 452 or 456 of the Code

applicable. The parameters for application of these sections are those as

are enumerated in the specific provisions. Sections 451 and 452

specifically define the expression ‘property’ for the purpose of an order of

custody and disposal by the Court. Section 456 applies to the category or

type of offences concerning immovable property regardless of whether the

immovable property is in custody of the Court or has been attached.

Power of the Criminal Court under these Sections, except Section 457 of

the Code, is not restricted to property seized by the police officer under

Section 102 of the Code. Section 457, as noticed, applies to properties

which have been seized by the police officer under the Code but not

produced during inquiry or trial.”

On considering the decision of the Apex Court in Nevada Properties

Private Limited (supra), we are of the view that the Apex Court has not

made any interpretation or laid down any law, with regard to whether Section

457 Cr.P.C would be applicable at the stage of investigation. Accordingly, the

decision made in the above case, in our view, is not applicable to the issue to be

decided herein.

Page No.# 22/31

33. In the case of Ambika Roy (supra) , the Division Bench of the Calcutta

High Court held that the words “and such property is not produced before a

Criminal Court during an inquiry or trial appearing in Section 457 Cr.P.C merely

referred to the stage of investigation and not the stage of inquiry or trial. As

such, once the factum of seizure of a property has been reported to a Court

under the provisions of Section 457 Cr.P.C, the Criminal Court could give custody

of the seized property at the investigation stage under Section 457 Cr.P.C. The

Calcutta High Court also held that if the property was produced in Court during

an enquiry and trial, then Section 451 Cr.P.C would apply and not Section 457

Cr.P.C.

34. In the case of Sunderbhai Ambalal Desai (supra), the Apex Court had

considered the judgment of the Apex Court in Smt. Basavva Kom

Dyamangouda Patil vs. State of Mysore & Another , reported in (1977) 4

SCC 358 and held that the Magistrate should take immediate action under

Section 451 Cr.P.C, to see that the seized articles were not kept at the police

station for more than fifteen days to one month from the date of seizure. There

was no decision made with regard to whether Section 457 Cr.P.C. could be

invoked by a Criminal Court for release of the seized articles.

In the case of Smt. Basava Kom Dyamangouda Patil (supra), the Apex

Court held in para 4 as follows:-

“4. The object and scheme of the various provisions of the Code appear to

be that where the property which has been the subject-matter of an

offence is seized by the police it ought not to be retained in the custody of

the Court or of the police for any time longer than what is absolutely

necessary. As the seizure of the property by the police amounts to a clear

entrustment of the property to a Government servant, the idea is that the

Page No.# 23/31

property should be restored to the original owner after the necessity to

retain it ceases. It is manifest that there may be two stages when the

property may be returned to the owner. In the first place it may be

returned during any inquiry or trial. This may particularly be necessary

where the property concerned is subject to speedy or natural decay. There

may be other compelling reasons also which may justify the disposal of

the property to the owner or otherwise in the interest of justice. The High

Court and the Sessions Judge proceeded on the footing that one of the

essential requirements of the Code is that the articles concerned must be

produced before the Court or should be in its custody. The object of the

Code seems to be that any property which is in the control of the Court

either directly or indirectly should be disposed of by the Court and a just

and proper order should be passed by the Court regarding its disposal. In

a criminal case, the police always acts under the direct control of the

Court and has to take orders from it at every stage of an inquiry or trial.

In this broad sense, therefore, the Court exercises an overall control on

the actions of the police officers in every case where it has taken

cognizance.”

The Apex Court in the case of Sunderbhai Ambalal Desai (supra) did

not go into the question whether Section 457 Cr.P.C. could be applied by a

Criminal Court during the stage of investigation. However, it held that seized

property should not be kept for more than a month at the police station.

35. In the case of P.V. Joseph vs. State, reported in 1978 CRI L.J. 1206,

the Kerala High Court has held that there is no bar in Section 457 Cr.P.C. from

exercising the power under it, at the stage of investigation.

36. In the case of Bharat Heavy Electricals (supra) , the Andhra Pradesh

High Court has held that the Criminal Court had the power under Section 457

Page No.# 24/31

Cr.P.C. for delivery or disposal of a property prior to filing of a charge-sheet.

However, it added a Caveat as follows:

“Even if I am wrong, I could still direct the delivery of the property to the

petitioner company under Section 482 Criminal P.C. in order to secure the ends

of justice.”

37. In the case of Joshy (supra), the Kerala High Court has held that as no

charge-sheet has been filed and the case was pending investigation, there was

no pending inquiry or trial. Accordingly no orders under Section 451 Cr.P.C.

could be passed. However, orders could be passed under Section 457 Cr.P.C.

38. In the case of Dheerendra Dwivedi @ Dheeru vs. State of M.P.,

Criminal Revision No.2078/2020, the Madhya Pradesh High Court at

Jabalpur has held that a Judicial Magistrate acquires jurisdiction to entertain an

application under Section 457 Cr.P.C., when a police officer seizes property and

the matter is under investigation before the police, but before the property is

produced before a Criminal Court during inquiry or trial. In such a condition, the

Magistrate may make an order for disposal of such property or delivery of such

property entitled to possession thereof.

39. In view of the conflicting decisions made by various High Courts, it would

be profitable to now consider the decision of the Apex Court in the case of

General Insurance Council & Others vs. State of A.P. & Others, reported

in (2010) 6 SCC 768. In the above case, the General Insurance Council had

approached the Apex Court for further directions, orders and clarifications with

Page No.# 25/31

regard to the violation of the directions passed by the Apex Court in

Sunderbhai Ambalal Desai (supra) , inasmuch as seized vehicles involved in

commission of various offences were not being released, thereby reducing

several hundred crores worth of assets to junk. The Apex Court in the above

case held that though the questions projected in the case had been answered

by the Apex Court in another case, i.e., Sunderbhai Ambalal Desai (supra),

pertaining to interpretation and mode of implementation of Section 451 and

Section 457 Cr.PC, certain grey areas had been left untouched. The Apex Court

thereafter, reiterated the observations of the Apex Court in Sunderbhai

Ambalal Desai (supra), wherein it had been held that it was no use in

keeping seized vehicles at Police Stations for a long period and it was for the

Magistrate to pass appropriate orders immediately, by taking appropriate bond

and guarantee as well as security for return of the seized vehicles, if required at

any point of time. Thereafter, the Apex Court in General Insurance Council

& Others (supra) gave additional directions, in addition to the directions given

in Sunderbhai Ambalal Desai (supra), after considering the mandate of

Section 451 read with Section 457 Cr.PC. Para 13 of the judgment of General

Insurance Council & Others (supra) is reproduced below as follows:-

“In our considered opinion, the aforesaid information is required to

be utilised and followed scrupulously and has to be given positively as and

when asked for by the Insurer. We also feel, it is necessary that in

addition to the directions issued by this Court in Sunderbhai Ambalal Desai

(supra) considering the mandate of Section 451 read with Section 457 of

the Code, the following further directions with regard to seized vehicles

are required to be given:

"(A) Insurer may be permitted to move a separate application for

release of the recovered vehicle as soon as it is informed of such recovery

before the Jurisdictional Court. Ordinarily, release shall be made within a

Page No.# 26/31

period of 30 days from the date of the application. The necessary

photographs may be taken duly authenticated and certified, and a

detailed panchnama may be prepared before such release.

(B) The photographs so taken may be used as secondary evidence

during trial. Hence, physical production of the vehicle may be dispensed

with.

(C) Insurer would submit an undertaking/guarantee

to remit the proceeds from the sale/auction of the vehicle conducted

by the Insurance Company in the event that the Magistrate finally

adjudicates that the rightful ownership of the vehicle does not vest with

the insurer. The undertaking/guarantee would be furnished at the time of

release of the vehicle, pursuant to the application for release of the

recovered vehicle. Insistence on personal bonds may be dispensed with

looking to the corporate structure of the insurer."

The Apex Court in General Insurance Council & Others (supra) has

thus held that an Insurer may be permitted to move an application for release

of the seized vehicles as soon as it is informed of such recovery before the

jurisdictional Court and that ordinarily, release should be made within a period

of 30 (thirty) days from the date of the application for release of the seized

vehicle. The above directions had been made on considering the mandate of

Section 451 and Section 457 Cr.PC.

40. In the case of Ram Prakash Sharma (supra), the Apex Court directed

the Criminal Court to pass appropriate orders under Section 457 Cr.P.C for

disposal of seized property during the investigation stage. In the above case,

the Apex Court has held that the Court has power to dispose of property seized

by the police but not yet produced before the Court under Section 457 Cr.P.C

and before charge-sheet had been submitted. The Apex Court had thereafter

taken into consideration the judgment of the Apex Court in Smt. Basava Kom

Page No.# 27/31

Dyamangouda Patil (supra), that the police or the Court should not keep the

seized property indefinitely in its custody. The Apex Court thereafter directed

the Special Court to pass appropriate order under Section 457 Cr.P.C for seized

property despite the case being in the investigation stage.

The extract of the judgment of the Apex Court in Ram Prakash Sharma

(supra) is reproduced below :

“3. ............ Be that as it may, the situation is squarely covered by Section

457 Cr.P.C. However, the fact that the court has power to dispose of

property seized by the police but not yet produced before the court does

not mean that the Special Judge must always release such property to the

person from whom the property has been recovered, especially when the

state of the case is in suspicion, the investigation is not over and chargesheet

has not yet been laid. The court has to be circumspect in such a

situation before releasing the property. While we reverse the decision of

the courts below that the Special Judge had no power to release the

seized property, we should not be taken to mean that whenever the

claimant asks for the property back, he should be given back the said

property. That has to be decided on its own merits in each case and the

discretion of the court has to be exercised after due consideration of the

interests of justice including the prospective necessity of the production of

these seized articles at the time of the trial. If the release of the property

seized will, in any manner, affect or prejudice the course of justice at the

time of the trial, it will be a wise discretion to reject the claim for return.

4. .................... All that we need do at the moment is to uphold the

power of the court to release the property and direct the Special Judge to

hold an investigation into the necessity for the notes seized to be retained

with the police or in the court for future use at the time of the inquiry or

trial. If he is of the opinion that the notes are so required, the property

shall not be released. If, on the other hand, the notes are not needed in

any manner in the later stages of the inquiry or trial, it will be proper for

the court to release the property on the appellant furnishing adequate

Page No.# 28/31

security.

5. In reaching the conclusion we have taken note of the decision of this

Court in Smt. Basava Kom Dyamangouda Patil ond v. State of Mysore &

Others (1977) 4 SCC 358 of course, the Police should not indefinitely keep

property in its custody nor need the court keep the property seized and

produced before it unduly long but this does not whittle down the need

for the court to be vigilant when an application is made for return of

property seized by the police as to the necessity of such property being

required in the future course of the trial.

6. Having regard to these circumstances, the court will pass appropriate

orders under Section 457 Cr.P.C. regarding the disposal of the property

seized by the police in this case. The Special Judge will dispose of the

matter expeditiously since considerable time has elapsed. The appeal is

disposed of accordingly.”

41. In the case of Visitor, AMU vs. K.S. Misra, reported in (2007) 8 SCC

593 and Nathi Devi vs. Radha Devi Gupta, reported in (2005) 2 SCC 271,

the Apex Court has held that that it is a well settled principle of interpretation of

the statute that it is incumbent upon the court to avoid a construction, if

reasonably permissible on the language, which will render the part of the

statute devoid of any meaning or application. The courts must always presume

that the legislature inserted every part thereof for a purpose and the legislative

intent is that every part of the statute should have effect. The legislature is

deemed not to waste its words or to say anything in vain and constructions

which attribute redundancy to legislature will not be accepted, except for

compelling reasons. It cannot add or subtract words to a statute or read

something into it which is not there. It cannot rewrite or recast legislation. It is

also necessary to determine that there exists a presumption that the legislature

has not used any superfluous words and that the real intention of the legislation

Page No.# 29/31

must be gathered from the language used.

42. In the case of M. Ravindran vs. Directorate of Revenue

Intelligence (supra), the Apex Court has held that in case of any ambiguity in

the construction of a penal statue, the Courts must favour the interpretation

which leans towards protecting the rights of the accused, given the ubiquitous

power disparity between the individual accused and the State machinery. The

Apex Court also held that this is applicable not only in the case of substantive

penal statutes but also in the case of procedures providing for the curtailment of

the liberty of the accused.

43. On a reading of Section 457 Cr.P.C, we find that the said provision coverers a wide spectrum and would apply to all kinds of seizures under the Cr.P.C. On a reading of the words “and such property is not produced before a Criminal Court during an inquiry or trial” appearing in Section 457 Cr.P.C, the same does not necessarily mean that the report of the seizure of property to a Magistrate would be given to the same Magistrate who would hold an inquiry of the case under Section 2(g) of the Code and the trial of the case. The report of the seizure of property could be to a different Magistrate than the one who would conduct the inquiry or trial. The report of the seizure of property under Section 457 Cr.P.C which has not been produced at the stage of investigation, could be to a Magistrate who may not have the jurisdiction to hold the inquiry or trial on the submission of the charge-sheet in the said case. As such, we are of the view that the power conferred under Section 457 Cr.P.C cannot be given a restrictive meaning, as the power under the said provision can be exercised by a Magistrate who has no power to hold an inquiry or trial of the case, in which the seized property is involved in.

44. The fact that the Hon’ble Supreme Court has given a direction to the learned Criminal Court to consider release of seized property/articles at the investigation stage under Section 457 Cr.P.C, shows that Section 457 Cr.P.C. can be applied by the Criminal Court at the investigation stage for release of seized

property.The submission made by the counsel for the appellant that the

judgment of the Apex Court in Ram Prakash Sharma (supra) did not

deliberate on the scope of Section 457 Cr.P.C, for granting custody of seized

property at the stage of investigation cannot be accepted by us. While different

situations and circumstances could arise in respect of seized property, one

situation that can arise is when the police submit a final negative report and the

police authorities fail to release custody of the seized property in terms of

Section 102 Cr.P.C. In that case, there would be no remedy for the aggrieved

person, except to approach the High Court under Section 482 Cr.P.C or Article

226 of the Constitution, which would be a difficult task for people living in far

flung areas and those belonging to the weaker sections of society. In that event,

Section 457 Cr.P.C would become redundant. After considering the decisions of

the Apex Court and the various High Courts alongwith Section 457 Cr.P.C, we

are of the considered opinion that the words “and such property is not produced

before a Criminal Court during an inquiry or trial”, appearing in sub-Section (1)

of Section 457 Cr.P.C, cannot be restricted to mean that the stage of inquiry or

trial is a condition precedent, for a Court to have jurisdiction for exercising

power under Section 457 Cr.P.C. at the investigation stage. We are of the view

that the words “and such property is not produced before a Criminal Court

during the inquiry or trial” appearing in Section 457(1) Cr.P.C would have to be


considered to be a reference to a stage of investigation and not the stage of

inquiry or trial. Further, we are bound by the decision of the Apex Court in Ram

Prakash Sharma (supra) , in terms of Article 141 of the Constitution of India,

as it is the mandate of the Constitution that the law declared by the Supreme

Court shall be binding on all Courts within the territory of India. Also, in the case

of Anil Kumar Neotia vs. Union of India & Others, reported in AIR 1988

SC 1353, it has been held that the High Court cannot question the correctness

of the decision of the Supreme Court, even though the points stated before the

High Court were not considered by the Supreme Court.

45. In view of the reasons stated above, we answer the reference by holding

that at the investigation stage, seized articles cannot be released by a Court

under Section 451 Cr.P.C. However, under Section 457 Cr.P.C., the Criminal Court

has the jurisdiction to give custody of seized property/articles at the stage of

investigation, when those seized property are not produced before the Court.

46. The reference is answered accordingly and the matters may be placed

before the appropriate Bench.


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