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Divisional Forest Officer & Anr vs G.V. Sudhakar Rao & Ors on 31 October, 1985

26. The Hon’ble Supreme Court in Divisional Forest Officer v. G.V. Sudhakar Rao [(1985) 4 SCC 573] affirmed that special provisions under statutes such as the Forest Act for confiscation override general CrPC 15/33 https://www.mhc.tn.gov.in/judis ( Uploaded on: 09/07/2025 07:58:23 pm ) Crl.A.(MD)No.192 of 2024 provisions. Confiscation under Section 44(2A) remained valid even after acquittal. The same logic applies here. The NDPS Act is a complete code for seizure and disposal. This reinforces the legal proposition that Section 52A NDPS Act prevails over Section 451 CrPC in cases of seized vehicles.
Supreme Court of India Cites 16 - Cited by 99 - A P Sen - Full Document
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