DR. PARTAP SINGH AND ANR. vs DIRECTOR OF ENFORCEMENT FOREIGN EXCHANGE REGULATION AND ORS

The Supreme Court upheld the legality of search warrants issued under Section 37 of the Foreign Exchange Regulation Act, 1973, affirming that an officer must have 'reason to believe' that relevant documents are secreted before issuing such warrants. The Court clarified that while the grounds for this belief need not be recorded in writing, they must be sufficient to justify the issuance of the warrant. The appeal was dismissed, affirming the High Court's decision that the search and seizure were lawful under the relevant statutes, including Section 132A of the Income Tax Act, 1961.