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J.K. Steelomelt (P) Ltd. vs Bses Rajdhani Power Ltd. on 24 April, 2007

(20) In the light of this evidence the reliance placed by the Ld counsel for the complainant on the consumption pattern analysis Ex. CW1/5 alone is not sufficient to establish the case of dishonest abstraction of energy against the accused in the absence of other evidence to establish that consumer was involved in dishonest abstraction of energy. Reliance can safely be placed upon the judgments in J.K. Steelomelt (P) Ltd Vs BSES Rajdhani Power Ltd and Jagdish Narayan VS North Delhi Power Ltd & Anr referred Supra.

Jagarnath Singh vs B. S. Ramaswamy on 22 September, 1965

26...........It is one thing to plead that the connected load is more than the sanctioned load but is another to say that in fact the connected load has been used throughout by the petitioner. This could be only verified by the actual consumption recorded in the meter. If, as is indicated in the inspection report, the meter wiring is OK and the disc is moving in the right direction then the actual units recorded will reflect how much of the connected load is in fact being used. Therefore, merely because the connected load is more than the sanctioned load, cannot lead to an automatic presumption that the entire connected load is being used by the consumer throughout the period." ii. In Jagdish Narayan VS North Delhi Power Ltd & Anr , 140 (2007) DLT 307 wherein it was held that :­ "24. The decision of the Hon'ble Supreme Court in Jagannath Singh Vs B.S. Ramaswamy, [ 1966] 1 SCR 885 in illustrative although there the Court was concerned with a criminal conviction for the offence of theft of electricity under Section 39 and 44 of the Indian Electricity Act, 1910. The approach to the requirement of proof of dishonest abstraction of energy is nevertheless relevant for the present case. The Hon'ble Supreme Court held that the existence of artificial means for abstracting energy can only give rise to a presumption that there had been a dishonest abstraction. The supplier would still have to show that the consumer is responsible for such tampering. In this case, it was contended that the existence of an open stud­hole on the meter was CC no. 134/08 (NDPL VS Jagmohan) Page no..........9/15 sufficient proof that dishonest abstraction of energy had been taken place. In answer to that contention, the Hon'ble Supreme Court observed as under:­ "A meter with an exposed stud­hole, without more, is not a perfected instrument for unauthorized taking of energy, and cannot be regarded as an artificial means of its abstraction. To make it such an artificial means, the tampering must go further, and the meter must be converted into an instrument for recording less than the units actually passing through it. A Check meter affords an easy method of proving that the consumer's meter is recording less than the units consumed and is being used as an artificial means for abstraction of the unrecorded energy. To bring home the charge under Section 39, the prosecution must also prove that the consumer is responsible for the tampering. The evidence adduced by the prosecution must establish beyond doubt that the consumer is guilty of dishonest abstraction of energy."
Supreme Court of India Cites 6 - Cited by 9 - R S Bachawat - Full Document
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