STATE OF JHARKHAND vs GOVIND SINGH

The Supreme Court ruled that under Section 52(3) of the Indian Forest Act, 1927, as amended by the Bihar Act 9 of 1990, there is no explicit provision allowing for the release of a vehicle seized for a forest offence upon payment of a fine in lieu of confiscation. The Court held that the High Court's interpretation allowing such a release was incorrect and contrary to established precedent, specifically referencing the Division Bench decision in Dilip Kumar Pandey v. The State of Bihar. Consequently, the appeal by the State of Jharkhand was allowed, and the High Court's order was set aside.