JAWALA RAM vs STATE OF PEPSU

The Supreme Court held that the levy of special canal charges under Rules 32 and 33 of the Sirhind Canal Rules, in conjunction with Section 31 of the Northern India Canal and Drainage Act, 1873, does not constitute a 'penalty' as defined under Article 20(1) of the Constitution. The Court found that the use of water by the appellants was not an 'offence', and thus the charges imposed were lawful. The appeal against the High Court's dismissal of the petition under Articles 226 and 227 was rejected, affirming the legality of the charges levied by the canal authorities.