SUSHIL KUMAR PORWAL AND ORS. vs VIPIN MANEKLAL AND ORS.

The Supreme Court interpreted the proviso to Section 71 of the Gold Control Act, 1968, clarifying that it does cover primary gold. The Court held that Ratanbai had conscious possession of the seized gold, affirming the Collector's decision to impose a penalty under paragraph 75 of the Gold Control Ordinance, 1968. The appeal was allowed, reversing the High Court's decision that had quashed the confiscation order.