MANGI LAL vs STATE OF MAHARASHTRA

The Supreme Court held that the order of forfeiture of Juar was illegal as the Maharashtra Jwar (Restriction on Purchase and Sale and Control of Movement) Order, 1964 does not authorize the court to forfeit Juar, only packages or receptacles. The court found that the Buldana District Juar (Price Control) Order does not empower the court to order forfeiture either. However, it upheld the validity of Rule 141(2) of the Defence of India Rules, 1962, stating it is within the powers conferred by Section 3(1) of the Defence of India Act, which prevails over inconsistent laws as per Section 43 of the Act.