JAGARNATH SINGH vs B. S. RAMASWAMY

The Supreme Court upheld the conviction of the appellant under Sections 39 and 44 of the Indian Electricity Act, 1910, and Rule 138 of the Indian Electricity Rules, 1956, for tampering with an electricity meter. The Court established that the appellant's liability was absolute under Rule 138 due to failure to ensure the seal remained intact. However, it clarified that the mere exposure of a stud hole on the meter cover does not constitute prima facie evidence of dishonest abstraction under Section 39, as it does not qualify as an artificial means of abstraction without further evidence.