Saturday, 25 January 2025

Supreme Court: Bald Allegation Of Non-Compliance of S. 52A of NDPS Act Won't Result In Acquittal Unless Foundational Facts Of Non-Compliance Proved

This Court in its recent decision in Bharat Aambale v. State of Chhattisgarh [2025 INSC 78] summarized the position of law as regards the scope of Section 52A of the NDPS Act and the consequences of any non-compliance of the same as under: -

“50. We summarize our final conclusion as under: -

(I) Although Section 52A is primarily for the disposal

and destruction of seized contraband in a safe manner yet

it extends beyond the immediate context of drug disposal,

as it serves a broader purpose of also introducing

procedural safeguards in the treatment of narcotics

substance after seizure inasmuch as it provides for the

preparation of inventories, taking of photographs of the

seized substances and drawing samples therefrom in the

presence and with the certification of a magistrate. Mere

drawing of samples in presence of a gazetted officer

would not constitute sufficient compliance of the mandate

under Section 52A sub-section (2) of the NDPS Act.

(II) Although, there is no mandate that the drawing of

samples from the seized substance must take place at the

time of seizure as held in Mohanlal (supra), yet we are

of the opinion that the process of inventorying,

photographing and drawing samples of the seized substance

shall as far as possible, take place in the presence of

the accused, though the same may not be done at the very

spot of seizure.

(III) Any inventory, photographs or samples of seized

substance prepared in substantial compliance of the

procedure prescribed under Section 52A of the NDPS Act

and the Rules / Standing Order(s) thereunder would have

to be mandatorily treated as primary evidence as per

Section 52A sub section (4) of the NDPS Act, irrespective

of whether the substance in original is actually produced

before the court or not.

(IV) The procedure prescribed by the Standing Order(s) /

Rules in terms of Section 52A of the NDPS Act is only

intended to guide the officers and to see that a fair

procedure is adopted by the officer in-charge of the

investigation, and as such what is required is

substantial compliance of the procedure laid therein.

(V) Mere non-compliance of the procedure under Section

52A or the Standing Order(s) / Rules thereunder will not

be fatal to the trial unless there are discrepancies in

the physical evidence rendering the prosecution’s case

doubtful, which may not have been there had such

compliance been done. Courts should take a holistic and

cumulative view of the discrepancies that may exist in

the evidence adduced by the prosecution and appreciate

the same more carefully keeping in mind the procedural

lapses.

(VI) If the other material on record adduced by the

prosecution, oral or documentary inspires confidence and

satisfies the court as regards the recovery as-well as

conscious possession of the contraband from the accused

persons, then even in such cases, the courts can without

hesitation proceed to hold the accused guilty

notwithstanding any procedural defect in terms of Section

52A of the NDPS Act.

(VII) Non-compliance or delayed compliance of the said

provision or rules thereunder may lead the court to

drawing an adverse inference against the prosecution,

however no hard and fast rule can be laid down as to when

such inference may be drawn, and it would all depend on

the peculiar facts and circumstances of each case.

(VIII) Where there has been lapse on the part of the

police in either following the procedure laid down in

Section 52A of the NDPS Act or the prosecution in proving

the same, it will not be appropriate for the court to

resort to the statutory presumption of commission of an

offence from the possession of illicit material under

Section 54 of the NDPS Act, unless the court is otherwise

satisfied as regards the seizure or recovery of such

material from the accused persons from the other material

on record.

(IX) The initial burden will lie on the accused to first

lay the foundational facts to show that there was noncompliance of Section 52A, either by leading evidence of

its own or by relying upon the evidence of the

prosecution, and the standard required would only be

preponderance of probabilities.

(X) Once the foundational facts laid indicate noncompliance of Section 52A of the NDPS Act, the onus would

thereafter be on the prosecution to prove by cogent

evidence that either (i) there was substantial compliance

with the mandate of Section 52A of the NDPS Act OR (ii)

satisfy the court that such non-compliance does not

affect its case against the accused, and the standard of

proof required would be beyond a reasonable doubt.”{Para 9}

10. From the above exposition of law, it is clear that the initial

burden lies on the accused to first lay the foundational facts to

show that there was non-compliance of Section 52A on a

preponderance of probabilities, either by leading evidence of its

own or by relying upon the evidence of the prosecution. In the

present case, no question whatsoever was put by the defence counsel to PW-7 as regards Section 52A of the NDPS Act. Moreover, apart from a mere bald assertion that there has been a contravention of the mandate of Section 52A of the NDPS Act, nothing cogent has been pointed out to us by the appellant herein that would show that there had been a violation of the requirements of Section 52A of the NDPS Act.

IN THE SUPREME COURT OF INDIA

CRIMINAL APPELLATE JURISDICTION

 CRIMINAL APPEAL NO.201 OF 2019

RAJWANT SINGH  Vs  THE STATE OF HARYANA 

Dated: 09th JANUARY 2025.

This appeal arises from the judgment and order dated

15.05.2018 passed by the High Court of Punjab and Haryana at

Chandigarh in CRA-S-2377-SB-2004 by which the High Court dismissed

the appeal filed by the appellant herein and thereby, affirmed the

judgment and order of conviction passed by the Special Court,

Kurukshetra dated 21.10.2004 holding the appellant herein guilty of

the offence punishable under Section 15 of the Narcotic Drugs and

Psychotropic Substances Act, 1985 (for short, “the NDPS Act”) and

sentenced him to undergo rigorous imprisonment for ten years with a

fine of Rs.1 lakh.

2. The case of the prosecution may be summarised as under:-

The police had information that the appellant herein and one

Dara Singh were dealing in narcotics. The information was that both

are drug peddlers. On 23.04.2002, a vigil was kept on the movements of the appellant herein and Dara Singh. According to the case of

the prosecution, the appellant herein was travelling in a Contessa

car bearing registration No.HR 01-E-0948. The car was intercepted.

The car was searched and the appellant was found to be the only

person in the car and he was on the wheels. From the rear seat of

the car, three bags filled with poppy straw were recovered and two

bags containing poppy straws were recovered from the trunk of the

car. The contraband was seized at the spot. The case against the

co-accused Dara Singh was that he was following the car on a

motorcycle. The trial court held Dara Singh guilty of the alleged

offence however, he came to be acquitted by the High Court.

3. At the end of the investigation, chargesheet was filed for the

offences enumerated above. The trial court framed charge to which

the appellant pleaded not guilty and claimed to be tried. The

prosecution examined in all eight witnesses. The prosecution also

led documentary evidence in support of its case. The further

submission of the appellant herein was recorded under Section 313

of the Code of Criminal Procedure, 1973. In the further statement,

the appellant said that he was falsely implicated in the crime.

4. The trial court ultimately held the appellant herein guilty of

the offence and sentenced him as above. The High Court dismissed

the appeal and affirmed the judgment and order of conviction. In

such circumstances, the appellant is here before this Court with

the present appeal.

5. We have heard Ms. Jaspreet Gogia, the learned counsel

appearing for the appellant-convict and Mr. Devendra Kumar Saini,

the learned counsel appearing for the State of Haryana.

6. The only argument canvassed before us by the learned counsel

appearing for the appellant is that the conviction could be said to

have stood vitiated because of non-compliance of Section 52A of the

NDPS Act. In support of her submission, she relied upon the

decision of this Court in the case of Mohammed Khalid and Another

vs. State of Telangana (2024) 5 SCC 393, more particularly, para

(26) therein. Para (26) reads thus:-

“26. Admittedly, no proceedings under Section 52-A of

the NDPS Act were undertaken by the investigating

officer PW 5 for preparing an inventory and obtaining

samples in the presence of the jurisdictional

Magistrate. In this view of the matter, the FSL report

(Ext. P-11) is nothing but a waste paper and cannot be

read in evidence. The accused A-3 and A-4 were not

arrested at the spot.”

7. We are of the view that Section 52A talks about the disposal

of seized narcotic drugs and psychotropic substances. Even for the

purpose of invoking Section 52A, a foundation has to be laid by

putting appropriate relevant questions in that regard to the

investigating officer. Out of the blue, the appellant cannot

contend that Section 52A was not complied with. We have looked into

the evidence of PW-7 – Mahavir Singh, ASI, who had at the relevant

point of time attached to the Kurukshetra Police Station. In his

examination-in-chief, he has deposed as under:-

“ On 23.4.2002 I was posted as ASI in Police station,

Babain. On that day, a telephonic information was

received in the police station to be effect that

Rajwant Singh @ Billu son of Mohinder Singh, Jat Sikh,

resident of Ambassi, District Ambala and Dara Saini,

resident of Machhrouli, District Kurukshetra are

habitual of smuggling of narcotics and that Rajwant

Singh on that date in car bearing registration no.

HR- 01E-0948 of sky blue colour and associate Dare

Salmi on his motorcycle make Rajdoot had gone to bring

the narcotics and would come through villages Dhantori,

Machhrouli, Kharindwa, Buhawa and would go in the area

of Barara and if the nakabandi would be held then they

could be apprehended with the narcotics. It was also

informed that the aforesaid car was for the smuggling

purpose. On receipt of this information I recorded the

formal FIR Ex. PE and formed a raiding party consisting

of HC Rohtash Singh, C-I Umed and me and held a

nakabandi on Yara-Buhawa road in a government jeep

driven by Constable Prem Singh. Prior to proceeding to

the place of nakabandi I had sent the special report to

the Higher officers. I had also made a request to send

a Gazetted Officer at the place of nakabandi. ASI/SHO

police station Babain and Dy. S.P. Anil Kumar Dhawan

reached at the place of nakabandi.

At 4.35 p.m. a contessa car bearing no.HR-O1E-0948

came from the side of village Yara followed by a

motorcycle make Rajdoot. The car was got stopped by

signal which was seine driven by accused Rajwant Singh

present in the court today. The motorcyclist on seeing

the car stopped by us turned back and fled away. The

car driver on interrogation told his name Rajwant Singh

@ Billu son of Mohinder Singh, Jat Sikh, resident of

Kambassi. He also told that the motorcyclist who was

following the car was his associate and his name was

Dara Saini of village Machhoruli. On checking of the

car three gunny begs were found lying on the rear seat

of the car whereas two gunny bees were found kept in

the dicky of the car. On checking Ore all the five

gunny bags were found to contain poppy husk. Two

samples of 250 grams each were taken out from each bag

and the residue poppy husk of each bag was found to be

36-500 Kgs. The samples of 250 grams were weighed with

the help of spring balance; whereas the residue were

weighed with the help of farsi kanda", The residue were

sealed on the respective gunny bags and the samples

were converted into parcels. The residues and the

samples were sealed with my seal MS, and the Dy. S.P.

also affixed his seal AKD and ASI Baljit Singh SHO P.S.

Babain affixed is seal DS on the samples, residues.

Specimen seal impressions of all the three seals was

prepared separately and then the sample residue and

specimen seal impression were taken into possession

vide recovery memo Ex.PD attested by HC Rohtash Kumar,

Constable Urned Singh and Dy. S.P. Anil Dhawan. I


handed over my seal to HC Rohtash Kumar; whereas the

SHO and the Dy. S.P. retained their seals with them

after use. The contessa car No.HR-O1E-0948 was also

taken into posses-ion vine recovery memo Ex.PD. I also

prepared the report Ex.PA under section 57 of the Act

and put up the same to Baljit Singh ASI/SHO. After the

recovery of the poppy husk notice EX. PF u/s 50 of the

Act was served upon accused Rajwant Singh to the effect

that poppy husk had been recovered from his possession

and if he wanted to he produced before a Gazetted

Officer. The accused Raj Want Singh vide his reply

Ex.PF/1 opted not to be produced before any Gazetted

Officer. The accused was arrested after serving him the

grounds of his arrest vide memo Ex.PG attested by HC

Rohtash Kumar and Constable Umed Singh. A memo of

personal search Ex.PG/1 was prepared at the time of

arrest of Rajwant Singh and a golden ring and a wrist

watch were taken into possession. I prepared the rough

site plan Ex.PH with correct marginal notes on it and

recorded the statement of the witnesses. On return in

the police station after completion of the

investigation at the spot, I deposited the case

property intact with the MHC and put the accused behind

the bar. On 24.4.2002 the accused got recorded his

disclosure statement Ex.PJ to the effect that he had

kept concealed 4 gunny bags of poppy husk in the Sugarcane field near G.T. road in the area of village

Dhantori and he could get the same recovered. But no

recovery could be effected from the sugar-cane field in

pursuance of the disclosure statement. On 2.5.2002 I

recorded the statements of MHC Balbir Singh, Constable

Rajiv Kumar and HC Baljit Singh. On 27.5.2002 the

accused was arrested in this case who had surrendered

in the Court. The residue case property is Ex.Pl which

consists of 5 gunny bags containing poppy husk and the

car no. HR-O1E-0948 is Ex.P2.

xxx by Shri J.S. Waraich, Advocate for Dara Saini,

and Shri Amit Choudhary, Advocate for Rajwant.

The secret information was received by me at 2:15

p.m. I took departure from the police station after

recording the formal FIR at 2.30 p.m. I had informed to

SHO Baljit Singh and at Head Quarter Kurukshetra

through wireless regarding this information with a

request to reach at the spot. The place of nakabandi

and recovery is at a distance of 9 K.M. from police

station Babain. We had reached at the place of

nakabandi at 3.10 p.m. the nakabandi was held by way of

parking the jeep on the road. The car was got stopped

by hand signal. It is correct that on signal the person

to whom the signal is made may stop or may flee away as

per the circumstances. The car was got stopped at 4.35

p.m. The independent witness could not be joined as

none was available on the road. Village Buhawa is

situated at a distance of 1 1/2 K.M. from the place of

recovery whereas village Yara is at a distance of 1

K.M. No person was present in the fields or on the road

at that time. No Sarpanch, Lambardar or Panch from

Villages Buhawa and Yara were summoned at the spot at

the time of nakabandi or thereafter. I had not sent any

specific information under section 42 to the Higher

authorities but I had sent the copies of FIR to the

Higher Authorities to serve as a special report. In

addition to that I had also informed SHO Babain and

head quarter (Police), Kurukshetra regarding the secret

information and holding of nakabandi. SHC Baljit Singh

was not present in the police station at the time of

receipt of secret information. He was in the field area

and he was informed through wireless. I do not know for

what purpose SHO had gone in the area. After our

arrival at the place of nakabandi first of all ASI/SHO

Baljit Singh reached there and thereafter Dy. S.P.

reached there. Dy.S.P. reached at the spot after 15

minutes of the arrival of the SHO. There were three

officials with the Dy. S.P. SHO was accompanied by one

Constable. The motorcyclist was at a distance of 200

yards from the car. It is correct that when we got

stopped the car the Motorcycle turned back and ran

away. Dare Saini was not earlier known to me. I do not

know if Dara Saini accused is a patient of paralyses

since 1998 or he is under the constant treatment of PGI

Chandigarh. The car was stopped by the accused Rajwant

Singh just near to us, on our signal. The car driver

did not try to run away. The spring balance was with me

in the investigating bag; whereas the farsi kanda was

brought from village Yara by Constable Prem Singh in

the jeep. I do not know from whom the farsi kanda was

borrowed. The owner of the farsi kanda was not called

at the spot. I do not remember the colour of farsi

kande again said it was of sky colour. Farsi kanda had

five weights i.e. 1 Kg., 2 Kg., 5 Kg., 10 Kg. 500

grams. It is correct that to weigh the weight of 1

quintal, 1 Kg. weight is used on farsi kanda. The each

bag was weighed separately. The weight spring was of 5

Kg. It was pen type and not watch type I affixed three

seals of mine on the samples and residues, three seals

were affixed by the SHO on them. The Dy. S.P. affixed

his one seal on each parcel. The seal of the SHO and of

mine were made of silver whereas the seal of Dy.S.P.

was some what of iron. My seal was square type

(CHAKAUR); whereas the seals of SHO was round; whereas

the seal of Dy.S.P. was not round but was of lengthy

shape. It took about 3 and a half hours in completing

the proceedings at the spot. There was the field of

Devi Chand Pandit in the Northern side, field of

Krishan Pandit in the Southern side and there are roads

in the Eastern and Western side. The description of the

surroundings of the place of nakabandi had been asked

by from a passers bye at my arrival at the place of

nakabandi. I did not ask the name of the passers bye.

We reached in the police station from the place of

nakabandi at about 8.00 p.m. It is correct that I had

mentioned the weight of the golden ring as 6 tola in

the memo of personal search. It is incorrect that

nothing was covered from the possession of accused. It

is further incorrect that the car was found parked

abundant. It is further incorrect that the number HRO1E-0948 was of a scooter. It is further incorrect that

on enquiry it was found that scooter was of Rajwant

Singh prior to this case. It is incorrect that I have

falsely implicated accused Rajwant Singh or Dara Saini

accused in this case. It is incorrect that I have

deposed falsely.”

8. We have looked into the entire cross-examination of PW-7 and

we do not find any question put by the defence counsel to PW-7 as

regards Section 52A of the NDPS Act.

9. This Court in its recent decision in Bharat Aambale v. State

of Chhattisgarh [2025 INSC 78] summarized the position of law as

regards the scope of Section 52A of the NDPS Act and the

consequences of any non-compliance of the same as under: -

“50. We summarize our final conclusion as under: -

(I) Although Section 52A is primarily for the disposal

and destruction of seized contraband in a safe manner yet

it extends beyond the immediate context of drug disposal,

as it serves a broader purpose of also introducing

procedural safeguards in the treatment of narcotics

substance after seizure inasmuch as it provides for the

preparation of inventories, taking of photographs of the

seized substances and drawing samples therefrom in the

presence and with the certification of a magistrate. Mere

drawing of samples in presence of a gazetted officer

would not constitute sufficient compliance of the mandate

under Section 52A sub-section (2) of the NDPS Act.

(II) Although, there is no mandate that the drawing of

samples from the seized substance must take place at the

time of seizure as held in Mohanlal (supra), yet we are

of the opinion that the process of inventorying,

photographing and drawing samples of the seized substance

shall as far as possible, take place in the presence of

the accused, though the same may not be done at the very

spot of seizure.

(III) Any inventory, photographs or samples of seized

substance prepared in substantial compliance of the

procedure prescribed under Section 52A of the NDPS Act

and the Rules / Standing Order(s) thereunder would have

to be mandatorily treated as primary evidence as per

Section 52A sub section (4) of the NDPS Act, irrespective

of whether the substance in original is actually produced

before the court or not.

(IV) The procedure prescribed by the Standing Order(s) /

Rules in terms of Section 52A of the NDPS Act is only

intended to guide the officers and to see that a fair

procedure is adopted by the officer in-charge of the

investigation, and as such what is required is

substantial compliance of the procedure laid therein.

(V) Mere non-compliance of the procedure under Section

52A or the Standing Order(s) / Rules thereunder will not

be fatal to the trial unless there are discrepancies in

the physical evidence rendering the prosecution’s case

doubtful, which may not have been there had such

compliance been done. Courts should take a holistic and

cumulative view of the discrepancies that may exist in

the evidence adduced by the prosecution and appreciate

the same more carefully keeping in mind the procedural

lapses.

(VI) If the other material on record adduced by the

prosecution, oral or documentary inspires confidence and

satisfies the court as regards the recovery as-well as

conscious possession of the contraband from the accused

persons, then even in such cases, the courts can without

hesitation proceed to hold the accused guilty

notwithstanding any procedural defect in terms of Section

52A of the NDPS Act.

(VII) Non-compliance or delayed compliance of the said

provision or rules thereunder may lead the court to

drawing an adverse inference against the prosecution,

however no hard and fast rule can be laid down as to when

such inference may be drawn, and it would all depend on

the peculiar facts and circumstances of each case.

(VIII) Where there has been lapse on the part of the

police in either following the procedure laid down in

Section 52A of the NDPS Act or the prosecution in proving

the same, it will not be appropriate for the court to

resort to the statutory presumption of commission of an

offence from the possession of illicit material under

Section 54 of the NDPS Act, unless the court is otherwise

satisfied as regards the seizure or recovery of such

material from the accused persons from the other material

on record.

(IX) The initial burden will lie on the accused to first

lay the foundational facts to show that there was noncompliance of Section 52A, either by leading evidence of

its own or by relying upon the evidence of the

prosecution, and the standard required would only be

preponderance of probabilities.

(X) Once the foundational facts laid indicate noncompliance of Section 52A of the NDPS Act, the onus would

thereafter be on the prosecution to prove by cogent

evidence that either (i) there was substantial compliance

with the mandate of Section 52A of the NDPS Act OR (ii)

satisfy the court that such non-compliance does not

affect its case against the accused, and the standard of

proof required would be beyond a reasonable doubt.”

10. From the above exposition of law, it is clear that the initial

burden lies on the accused to first lay the foundational facts to

show that there was non-compliance of Section 52A on a

preponderance of probabilities, either by leading evidence of its

own or by relying upon the evidence of the prosecution. In the

present case, no question whatsoever was put by the defence counsel

to PW-7 as regards Section 52A of the NDPS Act. Moreover, apart

from a mere bald assertion that there has been a contravention of

the mandate of Section 52A of the NDPS Act, nothing cogent has been

pointed out to us by the appellant herein that would show that

there had been a violation of the requirements of Section 52A of

the NDPS Act.

11. The reliance of the appellant herein on the decision of this

Court in Mohammed Khalid (supra) to assail the order of conviction

10

is completely misplaced. In the said, this Court had set-aside the

conviction of the accused therein not solely on the ground of noncompliance of Section 52A of the NDPS Act, but on the strength of

the other glaring loopholes in the prosecution’s case that made it

doubtful as to whether the samples drawn remained untampered or in

safe custody from the time of seizure till it reached the FSL. In

the said case, this Court found that the FSL report did not

disclose about the seals on the sample and although it was stated

that two samples were sent to FSL, yet in fact a total of three

samples had actually reached the lab.

12. In the present case, the High Court in its impugned judgment

and order of conviction had clear observed that after drawing the

samples from the seized substance, they were put into separate

parcels and were sealed bearing the initials of PW-7. Unlike

Mohammed Khalid (supra) there is nothing on record that would even remotely indicate that the samples that were drawn were not sealed or that the chain of custody of the said samples to the FSL was in any way compromised.

13. In such circumstances, we do not find any error much less any

error of law in the impugned judgment of the High Court. In the

result, this appeal fails and is hereby dismissed. We are informed

that so far the appellant has undergone four years of the sentence

imposed by the trial court. When this appeal came to be admitted at

the time of the admission of the appeal, he was ordered to be

released on bail. The appellant shall now surrender before the

trial court who in turn, shall hand him over to the jail

authorities for the purpose of serving his remaining part of the

sentence. He shall surrender within a period of four weeks from

today.

14. Pending application(s), if any, shall stand disposed of.

…………………………………………………………………………J.

 [J.B. PARDIWALA]

…………………………………………………………………………J.

 [R. MAHADEVAN]

NEW DELHI;

09th JANUARY 2025


Print Page

No comments:

Post a Comment