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K. Vijayakumar vs State Of Kerala Rep.By The on 19 February, 2016

In Vijayakumar v. State of Kerala : 2016 (1) KHC 698, when the police conducted a raid in a home stay, two ladies and some men were found in a room. Accused 1 and 2 in that case were conducting the home stay. The case was registered against them under Sections 3, 4(1), 5 and 7 of the Act. This court found that even if the allegation against the accused is Crl.M.C.No.7201/2016 14 taken at its face value, it cannot be found that they had committed any of the aforesaid offences and quashed the first information report by invoking the power under Section 482 of the Code.

Bai Radha vs State Of Gujarat on 20 November, 1968

In the light of the decision of the Apex Court in Bai Radha (supra), the plea that non-compliance with the requirement under Section 15(2) of the Act would vitiate the entire proceedings cannot be accepted. In many cases, due to various reasons, the police officer who conducts the search may Crl.M.C.No.7201/2016 7 not be able to procure the presence of a woman to witness the search. During the trial of the case, the police officer who conducted the search may show or explain the reason for non- compliance with the aforesaid provision. But, the accused will be entitled to plead and prove during the trial of the case that non- compliance with the provision contained in Section 15(2) of the Act has caused prejudice to him. Whether any such prejudice has been caused or not would depend on the facts and circumstances of each case. It is a matter in the realm of appreciation of evidence in each case.
Supreme Court of India Cites 19 - Cited by 28 - A N Grover - Full Document
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