NARCOTICS CONTROL BUREAU vs KRISHAN LAL AND OTHERS

The Supreme Court held that the powers of the High Court to grant bail under Section 439 of the Code of Criminal Procedure, 1973, are subject to the limitations imposed by Section 37(2) of the Narcotic Drugs and Psychotropic Substances Act, 1985. The Court clarified that the restrictions in Section 37, which are framed in negative terms, apply to the High Court as well, thereby limiting its bail granting powers. The judgment emphasized that special enactments like the NDPS Act take precedence over general provisions in the Cr.P.C. regarding bail.