BAI RADHA vs STATE OF GUJARAT

The Supreme Court upheld the conviction of the appellant under sections 3(1) and 4(1) of the Suppression of Immoral Traffic in Women and Girls Act, 1956, despite violations of sections 15(1) and (2) during the investigation. The Court ruled that while the special safeguards in section 15 must be adhered to, non-compliance does not automatically vitiate the trial unless it results in prejudice to the accused. The judgment clarified that the validity of a search is not solely dependent on the recording of reasons, and irregularities in the investigation do not affect the trial's outcome unless they cause a miscarriage of justice.