Supreme Court: registration certificate alone not sole factor for interim vehicle release

The case concerns a dispute between an appellant (director of M/s Pure Minerals) and the State of Andhra Pradesh/respondent company (M/s Earth Stein Private Limited) regarding who is entitled to interim custody of seized vehicles (one Bolero City Pick-up, 3 Excavators, and one Ashok Leyland Tipper) pending the resolution of criminal cases.

Who it concerns: Appellant: Krishnan Narayana; Respondents: State of Andhra Pradesh and M/s Earth Stein Private Limited; Bench: Justice Augustine George Masih.

What the court decided

• The Court framed the issue as determining who is entitled to interim custody of the subject vehicles under Sections 451 and 457 of the CrPC.
• The Court noted that Sections 451 and 457 CrPC vest the Court with the discretion to grant custody to whom it deems fit, emphasizing that the Court does not adjudicate title but grants interim possession to prevent decay or diminution in value.
• The Court cited precedents (N. Madhavan v. State of Kerala and Sunder Bhai Ambalal Desai v. State of Gujarat) stating that the exercise of this discretion must be judicial, reasonable, and just, considering the nature of the property and material on record.

Also in the document

• The judgment is marked as 'NON-REPORTABLE'.
• The High Court of Andhra Pradesh had previously granted interim custody of the vehicles to the respondent company, which the appellant is challenging.
• The appellant alleges the vehicles were seized illegally and that his resignation and undertaking were forged, while the respondents allege the appellant misappropriated company funds to purchase the vehicles in his own company's name.