STATE OF M.P. vs KEDIA LEATHER & LIQUOR LTD. .

The Supreme Court addressed the issue of whether Section 133 of the Code of Criminal Procedure, 1973 was impliedly repealed by the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981. The Court held that these statutes operate in different fields and can coexist, thereby affirming the validity of Section 133. The High Court's conclusion that the provisions of the Water and Air Acts impliedly repealed Section 133 was overturned, reinstating the SDM's jurisdiction under Section 133 to address public nuisance caused by pollution.