Mohd. Ismail Noor Mohammad vs Fehmada Nahid And Ors. on 13 November, 1964
12. Although the case of Nalluswami Reddi v. Nallammal AIR 1943 Mad 392, was a case under Section 517 of the Criminal P.C., Horwill J. laid down that a question of title as to property cannot be satisfactorily decided by a criminal Court; but where property prima facie is taken by violence by one person under the colour of a civil claim the criminal Court should ordinarily order the property so taken by violence to be returned to the person from whom it was taken.