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[Cites 22, Cited by 0]

Gujarat High Court

Bhavesh Jamnabhai Chawda & 5 vs State Of Gujarat & on 3 October, 2016

Author: S.G.Shah

Bench: S.G.Shah

                R/CR.RA/594/2016                                            CAV JUDGMENT



                    IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

             CRIMINAL REVISION APPLICATION (AGAINST ORDER PASSED BY
                             SUBORDINATE COURT) NO. 594 of 2016
                                             With
                     CRIMINAL REVISION APPLICATION NO. 627 of 2016
                                             With
                     CRIMINAL REVISION APPLICATION NO. 716 of 2016


         FOR APPROVAL AND SIGNATURE:


         HONOURABLE MR.JUSTICE S.G.SHAH

         ==========================================================

         1     Whether Reporters of Local Papers may be allowed
               to see the judgment ?

         2     To be referred to the Reporter or not ?

         3     Whether their Lordships wish to see the fair copy of
               the judgment ?

         4     Whether this case involves a substantial question of
               law as to the interpretation of the Constitution of
               India or any order made thereunder ?

         ==========================================================
                      BHAVESH JAMNABHAI CHAWDA & 5....Applicant(s)
                                       Versus
                         STATE OF GUJARAT & 1....Respondent(s)
         ==========================================================
         Appearance:
         MR VIKRAM CHAUDHARI, SENIOR ADVOCATE WITH MR HARDIK P
         MODH, ADVOCATE for the Applicant(s) No. 1 - 6
         MR RC KODEKAR for the Respondent No.2
         MR KP RAWAL, APP for the Respondent(s) No. 1
         ==========================================================

             CORAM: HONOURABLE MR.JUSTICE S.G.SHAH
                               Date : 03/10/2016
                                   COMMON CAV JUDGMENT


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         1.     Rule. Learned advocate Mr.R.C. Kodekar waives
         service of notice of rule for respondent No.2 and
         learned         APP        Mr.K.P.          Rawal          waives            service               of
         notice of rule for respondent No.1 - State.

         2.     Heard         learned          Senior            Counsel              Mr.        Vikram
         Chaudhari                 with learned Advocate Mr. Hardik P
         Modh      for      the      petitioners                and      learned             Standing
         Counsel Mr. R.C. Kodekar for CBI and learned APP
         Mr. K.P. Rawal for State. Perused the record.

         3.     These three petitions are though by different
         petitioners, they are arising                                    out of the same
         FIR      and       having         common             and       similar              disputes
         between the parties and therefore, they are heard
         and     decided            together          by        common          judgment.                  The
         advocates have also addressed only one set of
         arguments            for        all       the          three         petitions                    and
         practically               adopted        the         arguments             advanced                in
         first        petition            for       remaining                two        petitions.
         Therefore, the discussion is also recorded in one
         set      only        to      avoid         duplication                  of       work             and
         repetition            of     same        facts          separately                in      three
         separate judgments.

         4.     It      is         also     evident               from          records               that
         practically impugned order is also common in all
         these three revision petitions, being order dated
         20th     January,2010,                 below           an        application                      for
         discharging               the     petitioner                accused              from             the

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         charges leveled against them.

         5.     The sum and substance of the case against the
         petitioners are to the effect that petitioners
         being a public limited Company incorporated under
         the Companies Act, 1956 namely Welspun Gujarat
         Sthal Public Limited which name is changed to
         Welspun Corporation Limited (hereinafter referred
         to as the "Company") has filed an application for
         exemption,            pursuant           to     the          notification                   dated
         31st      July,           2001      by        the          Central              Government
         offering           exemption           from           the         excise            duty           to
         certain            units         under              specific                  terms                and
         conditions.               It   is     undisputed                   fact         that          said
         factory has its units at Anjar in Kutch and that
         the petitioners/persons had for the benefit of
         the Company at large and may be as per internal
         discussion            and      decision             of     the        Company,              while
         applying for such exemption declared that their
         units       had       started        commercial                  production.                  They
         have also disclosed the value of installed plant
         and machinery by way of producing a certificate
         issued by the Chartered Accountant and to prove
         the commercial production and transactions. They
         have also filed invoices alleged to have                                                      been
         issued by them prior to 31st December, 2005.

         6.     However, when the Assistant Commissioner of
         Central         Excise         had       visited              the        unit          of          the
         petitioner Company they found that the plant and


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         machinery were not fully installed and the unit
         was operated only                    for limited production and
         that it was the only possible production at the
         time      of     inspection          i.e.         2nd    January,              2006            and
         thereby         there       is     no     possibility                 of       any        more
         production and therefore the disclosure by the
         petitioner            Company       through             its      officers              being
         petitioner/persons, herein was not only false but
         fraudulent in as much as they want to declare
         themselves                eligible         under            the           terms                and
         conditions of the notification dated 31st July,
         2001, so as to get exemption from the payment of
         excise duty. It is further contended that even
         Chartered Accountants of the petitioner Company
         had issued false certificate claiming that the
         valuation of the plant and machinery installed is
         of Rs. 45.46 crores and Rs. 83.69 crores; though
         there was no such plant and machinery available
         on     the      day        of    inspection.              Therefore,                 it         is
         alleged          that       even        Chartered             Accountants                      had
         issued         such        installation              certificate                   without
         physically            verifying          the        plant        and        machinery.
         Therefore, as submitted, it is found that several
         documents are manipulated to get the exemption
         from      excise          duty     and      hence          investigation                       was
         conducted,            wherein       it      has         been        revealed              that
         several documents are forged and fabricated and
         therefore the complaint was lodged against the
         Company on 31st July, 2006. After investigation,



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         CBI     has       submitted          its         report           and         filed            a
         complaint against several accused under sections
         420, 467, 468, 471, 511, 120(b) of I.P.C. and
         Section 13(2) read with Section 13(1)(1)(d) of
         the Prevention of Corruption Act,1988. Amongst
         such accused, there is the Company itself, its
         Chairman, Managing Director and other officers so
         also Chartered Accountants.

         7.    Considering          the       investigation                  by       CBI,            the
         F.I.R        and         charge-sheet               runs           into            pages,
         disclosing           several        irregularities                    and        illegal
         activities alleged to have been committed by the
         petitioner Company and petitioner/persons. There
         are     several          communications               from         some          of          the
         officers and Chartered Accountants disclosing the
         compliance and certain terms and conditions of
         the notification under reference. But, mainly it
         was found that the contents of such communication
         are not correct.

         8.    Amongst the accused, the Managing Director of
         the Company namely B.K. Goenka had come forward
         and discussed the dispute with the department of
         Customs        and       Excise       conveying              that         it       was         a
         bonafide         error     or      mistake           on      their           part            and
         therefore he would like to settle the dispute
         with the department. It cannot be ignored that
         the basic ingredient of such settlement is the
         fact that practically Company has never received


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         any exemption from payment of tax, may be because
         of the fact that the documents were not in order.
         But, the fact remains that there was no financial
         benefit to the Company and nor to any of its
         office       bearers           or        officers               in       any         manner
         whatsoever.             It    is     also           undisputed              fact          that
         otherwise         also        the      benefit            if      any        is      to        be
         received,          it will go the Company and not to any
         individual and that the benefit to the Company
         would be ultimately to its shareholders and not
         to any particular individual in terms of any fix
         amount.

         9.   Pursuant to such attempt and exercise by B.K.
         Goenka, the Managing Director of the petitioner
         Company, the Customs and Excise Department had;
         considering             the        bonafides              of     the        petitioner
         Company and its office bearers, so also officers;
         agreed to settle the dispute and therefore now it
         would     not       be       necessary             to     recollect              all           the
         minute details of the F.I.R and charge-sheet, or
         the activities carried out by the petitioner for
         getting some advantage, more particularly when
         they have never received any advantage at all.

         10. The petitioner has also produced at Annexure
         P-11 on record, Order No. 01/CO/2008 dated 19th
         December         2008         by     the           Chief       Commissioner                    of
         Central        Excise          whereby               he        entered            into           a
         compromise and compounded the offence, if any,


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         committed by the petitioner Company or its office
         bearers. The perusal of such order,reveals that
         the Department had, after recording the facts of
         the      case        and         verification                    by      the        reporting
         authority while recording the findings makes it
         clear       that          the     applicant                before           it       i.e.            M/s
         Welspun          Corporation                   Ltd.,          Shri          B       K      Goenka
         Managing          Director            of        M/s          Welspun            Corporation
         Ltd. and Shri Mahesh Khemka Vice President of M/s
         Welspun         Corporation                   Ltd.         have        disclosed                true
         facts       relating             to       the       case       and        therefore                  the
         Chief       Commissioner                   grants           them         immunity               from
         prosecution under Section 9 of the Central Excise
         Act, 1944. While granting such immunity, it has
         been        recorded             that          the         basis         on       which              the
         Application for exemption was rejected is false
         information                furnished                by      the         Company               which
         constitutes an offence under Section 9(1)(c) of
         the Central Excise Act, 1944. Further, it was
         emphasized that the Company had not availed any
         benefit under the notification dated 31st July,
         2001      and      has       removed              the       cost        of       payment              of
         duties by utilization of                                 CENVAT Credit, thereby
         there       has           been     no          loss         of        revenue            to          the
         department by any act of the Company. Therefore,
         it     is     certainly               a       clear         position              that          when
         department            by        which           the        proceeding               has         been
         initiated has compounded the offence and that too
         by imposing condition to pay the amount for such



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         compounding                and           thereby              when             the          Chief
         Commissioner               of       Central             Excise        compounded                    the
         offence subject to the payment of Rs. 50,000/- by
         each of the applicant before it and that such
         amount is deposited by the concerned petitioners;
         there is no reason to proceed further in criminal
         trial when the department is not going to come
         and prove that the petitioner Company and persons
         have      obtained             any       illegal          and       undue           advantage
         from      them.           Though         the       legal         position             is       well
         settled on such issue and thereby though there is
         no need to continue the trial any further when
         CBI     has      filed          a    charge-sheet,                       initially                  the
         Managing Director of the petitioner Company Shri
         Balakrishna               Gopiram            Goenka          (B.K.Goenka)                           has
         challenged the proceeding in a quashing petition
         being Special Criminal Application No. 2543/2012,
         such petition was resisted by the State and CBI.
         The copy of judgment in such petition, dated 10th
         April,2015,               is        on      record          at        Annexure              P-20;
         perusal of which makes it clear that the Co-
         ordinate Bench has not only quashed and set aside
         the FIR qua the petitioner before it namely B.K.
         Goenka but has categorically observed that the
         purpose         of        compounding              of     offence            against                the
         payment         of        compounding                   amount        is       to       prevent
         litigation            and       encourage                 early         settlement                   of
         dispute as held by Hon'ble Supreme Court of India
         in the case of Rajesh Kumar Sharma v. Union of



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         India & Ors. Reported in (2007) 9 SCC 158, and
         Hira Lal Hari Lal Bhagwati v. CBI, New Delhi ,
         reported in (2003) 5 SCC 257, wherein Hon'ble
         Supreme Court has held that the petitioner is
         immune from any criminal proceedings pursuant to
         the certificate issued under                               the scheme.

         11. In        light        of     the        above        background,                 I      have
         considered the arguments canvassed on behalf of
         the learned advocates appearing for the parties.
         I have also gone through the documents produced
         on record. In the present case, the FIR came to
         be registered against one B. C. Macwana, the then
         Assistant Commissioner, Central Excise, Rajkot,
         M/s.      Welspun          Gujarat           Sthal        Rohren           Limited                and
         against           unknown           person               for          the           offences
         punishable under Sections 120B, 420, 467, 468,
         471     and       511       of    Indian              Penal       Code         and        under
         Section 15 of the Prevention of Corruption Act,
         1988.       After          the    investigation,                    a      charge-sheet
         came to be filed against the officers of the
         aforesaid                 Company            including                  the           present
         petitioners. The Company passed a resolution in
         its     Board         Meeting           and           decided         to       apply              for
         getting excise benefit as per Notification dated
         31.07.2001 and therefore the Company submitted an
         application               on     24.12.2005.               However,              from             the
         record,it appears that before the registration of
         the FIR, an application seeking withdrawal of the
         benefit,          which          was       sought          under           Notification

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         dated 31.07.2001, was submitted by the Company
         and, therefore, the Company has not received any
         wrongful           gain     on   the         basis           of       its         earlier
         application dated 24.12.2005 and therefore, no
         pecuniary loss is caused to the Department. Thus,
         the ingredients of the alleged offence punishable
         u/s. 420 of IPC are not attracted.

         12. It is also clear from the record and more
         particularly              from   the       order            dated          19.09.2008
         passed by the Chief Commissioner, Central Excise
         that      when        the    Central          Excise            Department                    had
         initiated the proceedings under Section 9 of the
         Central Excise Act against the Company and it
         officers          with      regard       to         the       similar             set          of
         allegations               made   in      the          impugned               FIR,             the
         department compounded the offence and therefore
         the allegations made in the proceedings initiated
         under Central excise Act have come to an end.
         Thus, when the Company and thereby its officers
         including           the     petitioners             have        compounded                    the
         offence,          initiation          of      proceedings                  under              the
         provisions of IPC for the same allegations cannot
         be     permitted.           There      cannot            be       two        different
         prosecutions for the same incident and petitioner
         cannot be prosecuted twice for the same offence
         even in different proceedings

         13. In the case of Rajesh Kumar Sharma v. Union
         of India & Ors., reported in (2007) 9 SCC 158,


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         The Hon'ble Supreme Court, in para 6, observed as
         under:

                  "6.   The         guidelines        for
                  compounding are contained in the
                  Circular No. 54/2005-Cus dated 30th
                  December, 2005.Central Government
                  had brought in to force the
                  Customs ( Compounding of Offences)
                  Rules 2005 (in- short the Custom
                  Rules')      and     Central     Excise
                  (Compounding of Offences ) Rules
                  2005)    (in    short   the    'Central
                  Excise Rules') with effect from
                  30th December, 2005. the purpose of
                  compounding the offences against
                  payment of compounding amount is
                  to     prevent      litigation      and
                  encourage     early    settlement    of
                  diputes.       The     cases      where
                  compounding would be rejected are
                  also    spelt    out   in    the   said
                  circular."


         14. In the case of Hira Lal Hari Lal Bhagwati v.
         CBI, New Delhi, reported in                     (2003) 5 SCC 257,
         The Hon'ble Supreme Court, in paras 29 and 30,
         observed as under:

                       "29.In our view, in the present
                       case,   the  alleged    criminal
                       liability stands compounded on
                       a settlement with respect to
                       the    civil     issues     and,
                       therefore,       the       First
                       Information      Report      was
                       erroneously   issued   and   was
                       totally unwarranted. From the
                       aforesaid     judgment,      the
                       proposition that follows in the

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                   instant case is that the Kar
                   Vivad Samadhan Scheme, 1998
                   issued by the Government of
                   India was a voluntary scheme
                   whereby if the disputed demand
                   is settled by the Authority and
                   pending       proceedings        are
                   withdrawn by an importer shall
                   be dropped and the importer
                   shall be immuned from the penal
                   proceedings under any law in
                   force. We are therefore, of the
                   opinion    that    this    judgment
                   squarely comes in the face of
                   any   argument     sought    to   be
                   propounded by the respondent
                   that the      Kar Vivad Samadhan
                   Scheme, 1998 does not absolve
                   the appellants from criminal
                   liability    under     the    Indian
                   Penal Codee. The learned Single
                   Judge of the High Court of
                   Delhi, in our opinion, has not
                   appreciated the fact that the
                   continuance of the proceedings
                   in the instant case would only
                   tantamount     to    driving     the
                   present appellants to double
                   jeopardy when they had been
                   honorably exonerated by the
                   Collector of Customs by their
                   adjudication and further the
                   GCS   of    which    one    of   the
                   appellants     is    the     General
                   Secretary in which capacity he
                   is accused in the present case
                   was granted amnesty under the
                   Kar   Vivad     Samadhan     Scheme,
                   1998.   In    our    opinion,    the
                   present case does not warrant
                   subjecting a citizen especially
                   senior citizens of the age of
                   92   &   70     years    to    fresh
                   investigation and prosecution

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                   on    an    incident     or    fact
                   situation giving rise to the
                   offence under both the Customs
                   Act and the Indian Penal Code
                   when the matter has already
                   been settled. Likewise, the
                   respondent herein has initiated
                   criminal    proceedings     against
                   Accused No. 2 & Accused No. 1,
                   inter alia , on the ground
                   alleging that the appellant in
                   conspiracy with the co-accused
                   named therein with each other
                   have cheated the Government of
                   India in terms of evasion of
                   Customs Duty and by concealment
                   of   facts    obtained    CDEC   in
                   respect of MRI and Lithotripsy
                   machines and by violating the
                   provisions     of    actual    user
                   condition as per Import Export
                   Policy and Customs Notification
                   No. 279/83 dated 30.9.1983 and
                   Customs Notification No. 64/88
                   dated 1.3.1988 during the year
                   1987-90, despite acknowledging
                   the fact that Customs Duty has
                   been paid by the appellants to
                   the   Customs     Department    and
                   settled and that commission of
                   offences under Section 120B
                   read with section 420 of the
                   Indian Penal Code are made out.
                   30.In our view, under the penal
                   law, there is no concept of
                   vicarious liability unless the
                   said statute covers the same
                   within    its    ambit.    In   the
                   instant case, the said law
                   which prevails in the field
                   I.e. the Customs Act,1962 the
                   appellants have been therein
                   under wholly discharged and the
                   GCS    granted     immunity    from

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                      prosecution.      It    is    well
                      established principle of law
                      that the matter which has been
                      adjudicated and settled need
                      not to be dragged into the
                      criminal    courts   unless    and
                      until the act of the appellants
                      could have been described as
                      culpable. The true fact and
                      import   of     the   Kar    Vivad
                      Samadhan Scheme, 1998, in our
                      view, is that once the said
                      Scheme is availed of and all
                      the formalities complied with
                      including the payment of the
                      duty,   the    immunity    granted
                      under the provisions of the
                      Customs Act,1962 also extends
                      to such offences that may prima
                      facie be made out on identical
                      allegations i.e. of evasion of
                      Customs Duty and violation of
                      any Notification issued under
                      the said Act."

         15. In     view        of    the       aforesaid               decisions,                    the
         learned      Senior         Counsel        is      right          in       submitting
         that in the present case once the offence is
         compounded under the provisions of the Central
         Excise Act and thereby the petitioner herein is
         granted       immunity           from            the      prosecution,                       the
         impugned FIR and the charge-sheet be quashed and
         set aside qua the petitioners also.

         16. In case of G.N.Verma v. State of Jharkhand                                                 &
         Anr., reported in                (2014) 4 SCC 282, the Hon'ble
         Supreme      Court,         in    para           18,      19,         20       and           25,
         observed as under:

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                  "18. It is nobody's case that
                  G.N. Verma was appointed as an
                  agent of any mine. Also, the
                  complaint does not allege or
                  state anywhere that G.N. Verma
                  acted or purported to act on
                  behalf of the owner of the mine
                  or that he took part in the
                  management,              control,
                  supervision or direction of any
                  mine. In fact his duties and
                  responsibilities have not been
                  described in the complaint. In
                  the   absence   of   G.N.Verma's
                  duties having been spelt out in
                  the complaint, it     is      not
                  possible to say whether he was
                  merely an administrative head
                  of Karkata Colliery being its
                  Chief General Manager or was he
                  required to be involved in
                  technical issues relating to
                  the     management,      control,
                  supervision or direction of any
                  mine in Karkata Colliery. The
                  averment in the complaint is
                  bald and vague and is to the
                  effect that at the relevant
                  time G.N. Verma was the Chief
                  General   Manager/deemed    agent
                  and was exercising supervision,
                  management and control of the
                  mine and in that capacity was
                  bound to see that all mining
                  operations were conducted in
                  accordance with the Act, the
                  Rules, Regulations, Orders made
                  thereunder.

                  19. It has been laid down, in
                  the context of Sections 138 and
                  141    of     the    Negotiable
                  Instruments    Act,   1881   in

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                  National      Small     Industries
                  Corpn. Ltd. v. Harmeet Singh
                  Paintal reported in (2010) 2
                  GLH 766 that Section 141 is a
                  penal    provision    creating    a
                  vicarious liability. It was
                  held as follows: (SCC p. 336,
                  para 13)
                      "13. ... It is therefore, not
                  sufficient     to   make   a   bald
                  cursory      statement     in     a
                  complaint that       the Director
                  (arrayed as an accused) is in
                  charge of and responsible to
                  the Company for the conduct of
                  the business of the Company
                  without anything more as to the
                  role of the Director. But the
                  complaint should spell out as
                  to how and in what manner
                  Respondent 1 was in charge of
                  or   was    responsible    to   the
                  accused Company for the conduct
                  of its business. This is in
                  consonance        with       strict
                  interpretation        of      penal
                  statutes,     especially,     where
                  such statutes create vicarious
                  liability."
                 (emphasis in original)

                 It was then concluded:
                 (SCC p. 345, para 39)
                "39.      (I)     The      primary
                responsibility     is    on    the
                complainant    to  make   specific
                averments as are required under
                the law in the complaint so as
                to make the accused vicariously
                liable.    For    fastening    the
                criminal liability, there is no
                presumption that every Director
                knows about the transaction."


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                20. Insofar    as    the   criminal
                complaint is concerned, it does
                not   contain     any    allegation
                against G.N. Verma. The only
                statement concerning him is that
                he   was   the     Chief    General
                Manager/deemed agent of the mine
                and was exercising supervision,
                management and control of the
                mine and in that capacity was
                bound to see that all mining
                operations   were    conducted   in
                accordance with the Act, the
                Rules, Regulations, Orders made
                thereunder. In the face of such
                a general statement, which does
                not   contain    any    allegation,
                specific or otherwise, it is
                difficult to hold that the Chief
                Judicial Magistrate rightly took
                cognizance of the complaint and
                issued summons to G.N. Verma.
                The law laid down by this Court
                in Harmeet Singh Paintal (though
                in another context) would be
                squarely applicable.

                    Under the circumstances, we
                are of the opinion that on the
                facts of this case and given the
                absence of any allegation in the
                complaint filed against him no
                case for proceeding against G.N.
                Verma has been made out.

                25. On the facts of this case,
                we would need to unreasonably
                stretch the law to include G.N.
                Verma as a person vicariously
                responsible for the lapse that
                occurred in the mine resulting
                in a fatal accident. We are of
                the   view   that  under   these
                circumstances, there is no basis

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                       for proceeding under Section 72B
                       of the Act against G.N. Verma."

         17. In        above          view        of       the         matter,             I      am         in
         agreement           with         the      argument             canvassed               by          the
         learned         Senior           Counsel         Shri         Chaudhari               for          the
         petitioner                that     since          there           is       no         specific
         allegation            in     the       FIR       or      in      the        charge-sheet
         against         the        petitioner            and        merely          because                the
         petitioners were employees of the Company, they
         have       been           implicated              in        the         offence,                   the
         petitioner cannot be made vicariously liable for
         the     act        and/or         omission             on      the        part         of          the
         Company         for        the     offence             punishable                under             the
         provisions            of     the       IPC.        Whereas            Department                   has
         already compounded the offence if any committed
         by the Company.

         18. The contention of the learned advocate Shri
         Kodekar appearing for respondent No.2 - CBI is
         that petitioners were members of the team of the
         Company which had tried to execute the resolution
         passed        by     the         Company         whereby            it      was        decided
         toapply for getting excise benefits as per the
         Notification dated 31.07.2001 and therefore the
         petitioners are involved in the aforesaid crime.
         However, the said contention is misconceived in
         view       of      the       fact          that          merely            because                 the
         petitioners were                       members of the team of the
         Company         and        Company           had         decided            to        give          an



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         application for getting the benefit of excise, it
         cannot be said that petitioners were having any
         intention to commit the alleged offence.

         19. In fact no specific role is attributed to
         each of the petitioner with regard to the alleged
         offence. Further, the Company has also decided to
         withdraw the application given for getting the
         benefit as per the Notification dated 31.07.2001
         and      therefore              the       Company               has           given             an
         application              for    withdrawal              on      17.07.2006                 i.e.
         before the registration of the FIR. Therefore, it
         cannot        be         said    that          the           petitioners                   have
         committed the alleged offence. Moreover, it is
         not the case of the CBI that petitioners have
         wrongfully gained anything and/or any wrongful
         loss is caused to the Department. The reliance
         placed by learned advocate Shri Kodekar on the
         statement of Shri Kuttan Mohanan Pillai is also
         misconceived in view of the fact that the said
         person is coaccused in the chargesheet which is
         filed against the Company and its officers. In
         the statement given by the said co-accused, no
         specific          allegations              are         made          by        the         said
         coaccused against the petitioner.

         20. In view of the aforesaid discussion, when it
         is prima facie proved that the petitioner has not
         wrongfully gained anything and/or any wrongful
         loss is caused to the Department and the Company


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         and its officers including the petitioners have
         been granted immunity, in the opinion of this
         Court, there is no need to continue with the
         criminal            prosecution             against                the           present
         petitioners. Moreover, neither in the FIR nor in
         the    charge-sheet            any      specific             allegations                     are
         leveled against the petitioners that they have
         forged any document. Even otherwise, looking to
         the     impugned           FIR     and           from        the         papers               of
         chargesheet,             the     ingredients                of       the         alleged
         offence are prima facie not made out.

         21. Thus, in view of the aforesaid discussion,
         the impugned FIR being RC20(A)/2008 - GNR and all
         proceedings              initiated          pursuant                thereto                  are
         nothing but a gross abuse of the process of the
         Court and therefore in the interest of justice,
         the    same       are     required         to       be      quashed            and           set
         aside. Accordingly, FIR being RC20(A)/2008 - GNR
         and the charge-sheet filed pursuant thereto are
         hereby quashed and set aside qua the petitioner.
         Rule is made absolute.

         22. The        petitioners           are         also        relying             on          the
         following           cases         which            are      confirming                  same
         principles that prosecution and proceedings after
         compounding              dispute           cannot               be          sustained
         therefore, further prosecution of such judgment
         has been avoided.




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                  (1)             1998 (108) E.L.T. 16 (S.C) G.L.
                                  DIDWANIA V. INCOME TAX OFFICER;
                  (2)             (2011) 2 SUPREME COURT CASES 703
                                  KOLLA         VEERA     RAGHAV     RAO
                                  V.GORANTALA VENKATESHWARA RAO AND
                                  ANOTHER;
                  (2)             (2004) 2 SUPREME COURT CASES 731
                                  K.C. BUILDERS     AND    ANOTHER    v.
                                  ASSISTANT   COMMISSIONER   OF   INCOME
                                  TAX;
                  (3)             (2015) 4     SUPREME COURT CASES 609
                                  SUNIL BHARTI MITTAL v.CENTRAL BUREAU
                                  OF INVESTIGATION;
                  (4)             (2013) 10 SUPREME COURT CASES 686
                                  CENTRAL BUREAU    OF INVESTIGATION v.
                                  JAGJIT SINGH;
                  (5)             (2013) 7 SUPREME COURT CASES 789
                                  MOHIT alias SONU AND     ANOTHER    v.
                                  STATE OF UTTAR PRADESH AND ANOTHER.

         23. As against that learned Advocate Mr. Kodekar
         for the CBI is relying on the decision reported
         in     (2013)10                SCC      686            Central              Bureau               of
         Investigation v. Jagjit Singh wherein Hon'ble the
         Supreme Court has held that settling the dispute
         with the bank is no ground to quash criminal
         proceedings against defaulter/loanee because such
         offences are not related to banking activities
         and    it      has        harmful         effect           on       public           and         it
         threatens the whole society and therefore though
         bank seems to be the victim society in general is
         victimized               and    hence         criminal               complaint                   was
         denied to be quashed only because                                            payment is
         made.      Whereas             in    the      present            case,           the        fact
         remains that in the present case, actually there
         is no default in making any payment but it is


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         only an attempt in getting any exemption from
         taxation and that was also not materialized and
         on   the     contrary          the      Managing              Director              of         the
         Company, the Company and its Vice President paid
         Rs.50,000/- each i.e. a total of Rs.1,50,000 for
         compounding             offences       thereby             practically                 there
         was benefit to the department and there was no
         benefit to the accused.

         24. Mr. Kodekar is also relying upon the decision
         in (2013) 7 SUPREME COURT CASES 789 between MOHIT
         alias SONU AND              ANOTHER              v.        STATE             OF        UTTAR
         PRADESH AND ANOTHER wherein Hon'ble Supreme Court
         has considered the revisional powers of the Court
         under        Section           397(2)                with          reference                    to
         interlocutory order and held that when there is
         specific        remedy         provided          by       way       of       appeal             or
         revision,          inherent          powers            under           section                 482
         cannot and should not be resorted to. Therefore,
         when the present petitions are not under Section
         482 of the Code for quashing the complainant but
         under Section 397 the Court has to verify the
         irregularity             and     illegality                 if        any         in           the
         impugned order. Hence, this judgment would not
         help the respondent.

         25. In support of such conclusion, reference to
         certain         judgments            of       the           Apex           Court               are
         necessary, which are as under:-




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         1.     AIR 1997 SC 2041 between State of Maharashtra
         Vs. Priya Sharan Maharaj - It is held that at the
         stage of framing the charge, the Court has to
         consider the material only with a view to find
         out that whether there is ground for presuming
         that accused has committed an offence or that
         there      is      no       sufficient             ground          for        proceeding
         against him and not to arrive at the conclusion
         that     whether            it   is     not        likely           to       lead         to       a
         conviction or not.

         2.     AIR      2000 SC          665     =     (2000)2 SCC                   57      between
         State of MP Vs. S.B. Johari - It was held that,
         the Court at the stage of S.227 and S.228 is not
         required to appreciate the evidence and arrive at
         the conclusion that the materials produced are
         sufficient           or     not    for       convicting                 the        accused.
         Only prima facie case is to be looked into. The
         charge can be quashed if the evidence which the
         prosecutor proposes to prove the guilt of the
         accused, even if fully accepted, cannot show that
         accused committed particular offence. Thus it is
         settled        law        that    at     the       stage          of      framing                the
         charge, the Court has to prima facie consider
         whether there is sufficient ground for proceeding
         against the accused. The Court is not required to
         appreciate            the        evidence              and       arrive             at           the
         conclusion                that    the        materials                produced                   are
         sufficient or not for convicting the accused. If


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         the Court is satisfied that a prima facie case is
         made out for proceeding further then a charge has
         to be framed. The charge can be quashed if the
         evidence which the prosecutor proposes to adduce
         to prove the guilt of the accused, even if fully
         accepted          before         it     is        challenged                 by       cross-
         examination or rebutted by defence evidence, if
         any,      cannot          show    that         accused              committed                   the
         particular offence. In such case there would be
         no    sufficient            ground        for         proceeding                with            the
         trial.

         3.     AIR 2005 SC 359: State of Orissa vs. Debendra
         Nath Padhi - The Apex Court has held that, it is
         seen     from        S.227       of    the        Code         that         in      a      case
         triable before the Court of Session, if the Court
         on consideration of the record of the case and
         the     documents            submitted            therewith                  and        after
         hearing the submission of the prosecution and the
         accused if the Judge considers that there is no
         sufficient            ground      for        proceeding                  against                the
         accused,         he       shall   discharge               the        accused            after
         recording reasons for doing so.

         4.     (1997)4 SCC 393 = 1997 AIR SCW 1833: State of
         Maharashtra vs. Priya Sharan Maharaj - Referring
         to the case of Niranjan Singh Karam Singh Punjabi
         1990 AIR 1962, 1990 SCR (3) 633 held that at the
         stage      of      Sections       227        and        228,         the        Court            is
         required to evaluate the material and documents


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         on record with a view to find out if the facts
         emerging there from taken at their face value
         disclose        the      existence       of      all       the        ingredients
         constituting the alleged offence. The Court may,
         for this limited purpose, sift the evidence as it
         cannot be expected even at that initial stage to
         accept all that the prosecution states as gospel
         truth and even if it is opposed to common sense
         or    the          broad    probabilities                   of         the         case.
         Therefore, at the stage of framing of the charge,
         the Court has to consider the material with a
         view to find out that whether there is any ground
         for presuming that the accused has committed the
         offence or that there is not sufficient ground
         for    proceeding          against         him        and        not         for           the
         purpose of arriving at the conclusion that it is
         not likely to lead to a conviction

         5.    AIR 2007 SC 2149 = 2007 AIR SCW 3683 - Soma
         Chakravarty v. State - It is held that before
         framing        a     charge    the        court           must          apply              its
         judicial mind on the material placed on record
         and   must         be    satisfied       that        the        commitment                  of
         offence by the accused was possible.


         6.    AIR 2012 SC 1890 - General Officer Commanding
         Vs.CBI - It is held that the cognizance has to be
         taken of the offence and not of the offender and
         that it is the duty of the investigating agency
         to collect and to produce cogent evidence against

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         the   accused            for   framing           charge         and        Court             can
         convict the accused only if such charges i.e.
         evidence is proved on record without reasonable
         doubt. Therefore, if there is no chance to prove
         a commission of offence by the accused, charge
         cannot be framed.

         7.    AIR     2009 SC          (Suppl) 1744 -                    State         of      M.P.
         Vs.Sheetla Sahai - It is held that if the Court
         arrives at only opinion, there is no evidence
         against       the        accused,      the         Court        shall          not           put
         accused to harassment by asking him to face a
         trial.

         26. Thus, the law on the subject is now well
         settled, that while framing charge, the Court is
         required to evaluate the material and documents
         on record with a view to finding out if the facts
         emerging         therefrom        taken          at      their          face         value
         disclose         the      existence        of      all       the        ingredients
         constituting the alleged offence. The Court may,
         for this limited purpose, sift the evidence as it
         cannot be expected even at that initial stage to
         accept all that the prosecution states as gospel
         truth even if it is opposed to common sense or
         the broad probabilities of the case. Therefore,
         at the stage of framing of the charge, the Court
         has to consider the material with a view to find
         out if there is ground for presuming that the
         accused has committed the offence or that there


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         is no sufficient ground for proceeding against
         him and not for the purpose of arriving at the
         conclusion that whether it is likely to lead to a
         conviction or not.

         27.   However it cannot be ignored that what is to
         be    looked         into       is       "a      very          strong           suspicion
         founded        upon       materials             before           the        Magistrate,
         which leads him to form a presumptive opinion as
         to    the      existence          of         the        factual             ingredients
         constituting the offence alleged"; therefore                                                     it
         cannot       be      said       that         even         if       in       absence              of
         suspicion, presumptive opinion of the commission
         of offence as alleged, charge must be framed.
         Suffice        to        say    that         when         enactment                /statute
         provides          for          discharging               accused,               basically
         accused has a right to get discharge, which may
         be subject to fulfillment of certain criteria,
         that may be laid down either in the statute as
         well as its interpretation by the Apex Court and
         not otherwise. Therefore, there can be order of
         discharge if there is no evidence with charge
         sheet which gives rise to even a slight suspicion
         to    presume            the    commission               of      offence             by          the
         accused. Needless to say that even if there is
         suspicion regarding commission of offence, what
         is required to frame discharge is suspicion of
         commission of offence by the accused against whom
         charge sheet is filed. Thus even if suspicion is
         possible for commission of offence, and if there

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         is no evidence to link such suspicion with the
         accused, there cannot be a presumption against
         the accused that he had committed the offence and
         he may be entitled to get discharged from the
         charges        levied      against          him        under           the        charge
         sheet. Needless to say that the charges levied
         against the person is to be considered and not
         the story or history of incident which results
         into the commission of offence. For more clarity,
         commission of offence alone is not sufficient to
         frame charge against any person, there must be
         some suspicion that offence had been committed by
         the said person and not by any other person. If
         the    suspicion          is    to      the        effect            that         though
         offence        has       been   committed,                probably              accused
         might have not committed such offence but real
         offender may be someone else, Court has to see
         that truth comes out whereby the Investigating
         Agency may not be permitted to put their hands
         down merely by filing charge sheet against any
         one including any innocent person. In such cases,
         trial cannot be allowed to continue only upon
         opinion of the investigating agency that accused
         had committed the offence as alleged in charge
         sheet. The Court has to arrive at independent
         opinion, after considering the available prima
         facie evidenced on record - which is in the form
         of papers with the charge sheet, not only tabular
         charge       sheet       but    list      of      witnesses               and       their



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         statement before the investigating agency (police
         papers).           It      is     the         Court's              duty          to       frame
         independent opinion regarding not only commission
         of crime but involvement or role of the accused
         against whom charge sheet is filed and if there
         is    no      possibility                of       even          little           suspicion
         against         the        accused            regarding               commission                   of
         offence by him, there is no bar to discharge such
         person from the charges leveled against him. In
         such cases, it would be open for the original
         complainant and the investigating agency to keep
         such person under suspicion but to investigate
         further so as to find out real culprit, else
         filing        of         charge       against              a     person            only            on
         suspicion but without sufficient evidence against
         him would be a futile exercise and it will not
         only increase unnecessary workload but crime in
         the society also, since real culprits are able to
         get secluded them from the trial.

         28.   If      we         peruse       the         impugned              judgment,                  it
         becomes        clear        that          the         special           judge           mainly
         relied upon the facts discussed in the FIR and
         charge-sheet,              but    failed              to       realize          the       legal
         position in the case of compromise or compounding
         of offence by the parties. There is no need to
         proceed        further           in       criminal              proceedings.                      The
         Trial Court has also failed to appreciate the
         factual        details          that        in        fact       the       Company                has
         never been benefited by seeking exemption of tax

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         and that now there is one final judgment in favor
         of    the       Company             and     against             the         prosecuting
         agency.        But        the       determination                  of       co-ordinate
         bench       which         is        recollected               herein            above            is
         certainly applicable to all the accused and it
         cannot be said that it is applicable to only the
         person         who            has      preferred                 such           petition.
         Therefore,               when       the       complainant                  is        already
         quashed        against           the      Managing             Director              of          the
         Company         and       when       the         Company             and        its         Vice
         President has also compounded the offence with
         department on payment of compounding charges, it
         cannot be said that there is sufficient material
         and     ground           to      continue              with        the        proceeding
         against remaining accused who are practically not
         concerned with the final benefit if any received
         by the Company. When factually Company has never
         received         any          financial          benefit             it       cannot             be
         ignored that the present petitioner Company, and
         officers         of       the       Company            have        to       follow               the
         instructions               and       directions                of        the         Company
         through its chairman and Managing Director and
         when Chairman has been                       relieved from the charges
         on compounding the offences so also the Company,
         it    cannot             be     said        that          its          officers                  can
         separately prosecuted. At the most department or
         investigating agency may ask for penalty in the
         form of compounding charges from all the accused.

         29. It is undisputed fact that Central Excise Act

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         and Rules provides for compounding the offences
         so   also        section             320      of       Cr.PC.            It       is        also
         undisputed              fact     that          once          main          offence                is
         compounded then there is catana of judgments by
         Supreme        Court           that        when        the         department                    has
         compounded the offences then there is no reason
         to    continue            the        criminal              proceedings,                     more
         particularly when offences are either in the form
         of breach of rules or technical offences. In the
         present case, though some documents are alleged
         to be forged practically there is no forgery of
         any documents. It is submitted by the petitioners
         that, in fact an advance appreciation of work by
         the Company as per project report happens as per
         fixed     schedule             was    disclosed.                However            for           one
         reason or another if such time schedule could not
         be   adhered            to     either          during            installation                     or
         during       production               it        may              not         amount               to
         committing offence of forgery, since there is no
         means rea and practically there is no financial
         benefit accrued by any of the petitioners.

         30. In support of such conclusion, reference to
         certain         judgments              of        the          Apex           Court               are
         necessary, which are as under.


         (1) AIR 1997 S.C. 2041: State of Maharashtra vs.
         Priya Sharan Maharaj -

         It   is   held          that     at      the         stage        of      framing                the



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         charge, the Court has to consider the material
         with a view to find out if there is ground for
         presuming that accused has committed an offence
         or     that       there      is     no        sufficient                   ground               for
         proceeding against him and not for the charges by
         arriving at the conclusion that it is not likely
         to lead to a conviction.

         (2) AIR 2000 SC 665 = 2000 SCC(2) 57 : State of MP
         vs. SB Johari -

         It was held that, the Court at the stage of S.227
         and    S.228         is    not    required               to       appreciate                    the
         evidence and arrive at the conclusion that the
         materials          produced       are        sufficient                  or       not           for
         convicting the accused. Only prima facie case is
         to be looked into. The charge can be quashed if
         the    evidence           which    the        prosecutor                 proposes                to
         prove the guilt of the accused, even if fully
         accepted, it cannot show that accused committed
         that particular offence. Thus it is settled law
         that     at     the       stage   of      framing              the       charge,                the
         Court has to prima facie consider whether there
         is sufficient ground for proceeding against the
         accused. The Court is not required to appreciate
         the evidence and arrive at the conclusion that
         the materials produced are sufficient or not for
         convicting the accused. If the Court is satisfied
         that      a      prima      facie         case           is        made          out            for
         proceeding            further      then           a      charge            has        to        be
         framed. The charge can be quashed if the evidence

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         which the prosecutor proposes to adduce to prove
         the guilt of the accused, even if fully accepted
         before it is challenged by cross-examination or
         rebutted by defence evidence, if any, cannot show
         that accused committed the particular offence. In
         such case there would be no sufficient ground for
         proceeding with the trial.

         (3) 2005 SC 359: State of Orissa vs. Debendra Nath
         Padhi -

         The Apex Court has held that, it is seen from
         S.227 of the Code that in a case triable before
         the     Court            of   Session,             if         the          Court              on
         consideration of the record of the case and the
         documents submitted therewith and after hearing
         the submission of the prosecution and the accused
         if    the        Judge        considers            that          there            is          no
         sufficient           ground      for       proceeding                 against                the
         accused,        he       shall   discharge             the        accused            after
         recording reasons for doing so.

         (4) (1997) 4 SCC 393 = 1997 AIR SCW 1833: State of
         Maharashtra vs. Priya Sharan Maharaj -

         Referring to the case of Niranjan Singh Karam
         Singh Punjabi (supra) held that at the stage of
         Sections 227 and 228, the Court is required to
         evaluate        the       material       and       documents               on      record
         with a view to find out if the facts emerging
         there from taken at their face value disclose the
         existence of all the ingredients constituting the


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         alleged offence. The Court may, for this limited
         purpose,          sift      the     evidence              as       it       cannot             be
         expected even at that initial stage to accept all
         that the prosecution states as gospel truth and
         even if it is opposed to common sense or the
         broad probabilities of the case. Therefore, at
         the stage of framing of the charge, the Court has
         to consider the material with a view to find out
         that whether there is any ground for presuming
         that the accused has committed the offence or
         that       there           is     not       sufficient                  ground                 for
         proceeding against him and not for the purpose of
         arriving at the conclusion that it is not likely
         to lead to a conviction.

          (5) AIR 2007 SC 2149 = 2007 AIR SCW 3683 - Soma
         Chakravarty v. State -

         It is held as under: Before framing a charge the
         court       must          apply    its        judicial               mind         on           the
         material placed on record and must be satisfied
         that the commitment of offence by the accused was
         possible.

         (6) AIR 2012 SC 1890                 - General Officer Commanding
         Vs.CBI

         It is held as under: The cognizance has to be
         taken of the offence and not of the offender and
         that it is the duty of the investigating agency
         to collect and to produce cogent evidence against
         the    accused            for   framing            charge         and        Court             can


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                R/CR.RA/594/2016                                                    CAV JUDGMENT



         convict the accused only if such charges i.e.
         evidence is proved on record without reasonable
         doubt. Therefore, if there is no chance to prove
         a commission of offence by the accused, charge
         cannot be framed.

         (7) AIR 2009 SC Supplimentary 1744                                          - State of
         M.P. Vs.Sheetla Sahai


         It is held as under: if the Court arrives at only
         opinion,         there          is      no           evidence            against                 the
         accused,        the       Court        shall           not       put        accused               to
         harassment by asking him to face a trial.


         31. In view of above facts and circumstances, the
         revision           applications                 are          allowed.                Thereby
         impugned order dated 20.01.2010 charge-sheet to
         proceed further against petitioners are hereby
         quashed         and        set       aside             which          results               into
         discharging              the    petitioners                from         the        offences
         registered against them pursuant to complaint no.
         RC/20(A) /2008/GNR and charges leveled against
         them in CBI Special case No. 3/2010.

         3A.    Amongst            the       accused            at       present             we           are
         concerned with accused no. 3 as petitioner no. 2
         in revision petition no. 594/2016 whereas accused
         no.5 as petitioner no. 2 in Revision petition no.
         627/2016 accused no. 8 as petitioner no. 2 in
         Revision petition no. 627/2016 accused no. 9 as
         petitioner           no.        3     in        Revision               petition                  no.

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                  R/CR.RA/594/2016                                                 CAV JUDGMENT



         627/2016 whereas petitioner in revision petition
         no.     716/2016             is    accused          no.       1.       Complaint                is
         already quashed and accused no. 2 whereas it is
         abated so far as accused no. 14.

         3B. Learned                advocate        for        the       petitioner                 also
         disclosed that petitioners in revision petition
         no. 716/2016 have also preferred Special Criminal
         Application under Section 482 but considered the
         decision of Mohit (Supra). They have selected to
         file separate revision.

         3C. At present the petitioners have challenged
         the order dated 20th January 2010 where by Special
         Court        has       ordered        to       issue           process             and          to
         initiate criminal proceedings. However in view of
         the development on factual side , quashing of FIR
         and      order             dated    10th       April,2015                 in        Special
         Criminal          Application           No.         2543/2012              petitioners
         are right to challenge such order and praying to
         remove the proceedings against them.

         32. Rule is made absolute
          
                                                                                      (S.G.SHAH, J.)
         binoy




                                               Page 36 of 36

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                   R/CR.RA/594/2016                                              ORDER



                  IN THE HIGH COURT OF GUJARAT AT AHMEDABAD

           CRIMINAL REVISION APPLICATION (AGAINST ORDER PASSED BY
                           SUBORDINATE COURT) NO. 594 of 2016


              [On note for speaking to minutes of order dated 03/10/2016 in
                                R/CR.RA/594/2016 ]
                                      With
                   CRIMINAL REVISION APPLICATION NO. 627 of 2016
                                            With
                   CRIMINAL REVISION APPLICATION NO. 716 of 2016
         ==========================================================
                    BHAVESH JAMNABHAI CHAWDA & 5....Applicant(s)
                                     Versus
                       STATE OF GUJARAT & 1....Respondent(s)
         ==========================================================
         Appearance:
         MR HARDIK P MODH, ADVOCATE for the Applicant(s) No. 1 - 6
         PUBLIC PROSECUTOR for the Respondent(s) No. 1
         ==========================================================

          CORAM: HONOURABLE MR.JUSTICE S.G.SHAH

                                     Date : 20/10/2016


                                      ORAL ORDER

Perused the note. Heard learned advocate Mr. Hardik P. Modh for the petitioners. He has pointed out that in para 5 and 10 of the order dated 03.10.2016, the name of the company is wrongly stated as Welspun Corporation Limited, which is to be read as Welspun Corp. Limited.

Similarly, in the last line of para 6 "so far as Chartered Accountant", which is wrongly disclosed. Therefore, these words are also deleted.





                                          Page 1 of 2

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                      R/CR.RA/594/2016                                            ORDER




Similarly, in para 3(A) there is reference of some of the accused, the petition is allowed, so far as all the petitioners are concerned, and it would not make any difference in final decision.

Note for speaking to minutes if allowed to that extent and disposed of accordingly.

(S.G.SHAH, J.) drashti Page 2 of 2 HC-NIC Page 38 of 38 Created On Fri Oct 21 02:06:58 IST 2016 38 of 38