Shanti Kumar Panda vs Shakutala Devi

The Supreme Court held that the proceedings under Section 145(1) of the Code of Criminal Procedure, 1973 must allow all parties with a legitimate interest in the property to be heard, as failure to do so violates principles of natural justice. The Court found that Shakuntala Devi, who was not made a party to the proceedings, had a right to be heard regarding her possession of the shop. Consequently, the Court set aside the orders of the S.D.M. and the High Court, emphasizing that the respondent's right to due process was infringed.