Supreme Court of India

Mohanlal v. The State of Punjab

Neutral citation

Reported as [2018] 9 S.C.R. 1006

Bench Ranjan Gogoi, R. Banumathi and Navin Sinha JJ.

Decided 16 August 2018

Status Overruled

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

8 Supreme Court benches have cited this judgment.

What the Court ordered

We are of the opinion that merely because a detecting officer himself is investigating officer or the officer of the same ranks as that of the detecting offic er is investigating the case and files report before the Court will not vitiate the proceedings under N.D.P.S. act in the absence of proof of specific prejudice to the accused.

Judgment, page 17

From the headnote

Narcotic Drugs and Psychotropic Substances Act, 198 5: Fairness and impartiality in investigation – Inform ant and investigator, if same person – Sanctity of such inv estigation – Whether in a criminal prosecution, it will be in consonance with the principles of justice, fair play and a fair investi gation, if the informant and the investigating officer were to be the same person – Held: If an informant police official in a crimin al prosecution, especially when carrying a reverse burden of proof, makes the allegations and is himself asked to investigate, serious doubts would naturally arise

Authorities it was built on

2008 Noor Aga v. State of Punjab & Anr. cited by 27
1999 The State of Punjab v. Baldev Singh cited by 27
2010 Babubhai v. State of Gujarat & Ors. Etc. cited by 17
2004 State Rep. by Inspector of Police, Vigilance & Anti-corruption, Tiruchirapalli, Tamil Nadu v. V. Jayapaul cited by 7
1991 Rajangam, Secretary, District Beedi Workers Union and Ors. v. State of Tamil Nadu and Ors. cited by 6
2011 Bhola Singh v. State of Punjab cited by 4
2009 Bhaskar Ramappa Madar and Ors. v. State of Karnataka cited by 4
2016 Surender @ Kala v. State of Haryana cited by 2

Where later benches applied it

2025 State of Punjab v. Gurnam @ Gama Etc. referred to
2020 Tofan Singh v. State of Tamil Nadu referred to
2020 Rajesh Dhiman v. State of Himachal Pradesh referred to
2020 Rizwan Khan v. The State of Chhattisgarh referred to
2020 Surinder Kumar v. State of Punjab referred to
2020 Mukesh Singh v. State (narcotic Branch of Delhi) overruled
2019 The State of Telangana v. Sri Managipet @ Mangipet Sarveshwar Reddy not applicable
2019 Tarun Jit Tejpal v. The State of Goa & Anr. not applicable

Of those, 5 referred to · 1 overruled · 2 not applicable

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