State Of M.P vs Kedia Leather & Liquor Ltd. & Ors

The Supreme Court examined whether the enactment of the Water (Prevention and Control of Pollution) Act, 1974, and the Air (Prevention and Control of Pollution) Act, 1981, resulted in the implied repeal of Section 133 of the Code of Criminal Procedure, 1973. The High Court had previously held that these specialized environmental laws superseded the SDM's powers under Section 133. The Supreme Court questioned this view, analyzing the coexistence of general preventive powers and special statutory frameworks for pollution control.