STATE OF BIHAR vs BHAGIRATH SHARMA & ANOTHER

The Supreme Court dismissed the appeal under Article 134(1)(c) of the Constitution, holding that tyres and tubes of motor cars were not explicitly included in the scheduled items of the Bihar Essential Commodities Act, 1967. The Court emphasized the principle of fair warning in criminal jurisprudence, stating that dealers must have reasonable certainty regarding their obligations to avoid criminal liability. The Court also clarified that the certificate under Article 134(1)(c) should not be granted as a matter of course but requires exceptional circumstances, which were not present in this case.