Union Of India And Ors vs Mohanlal Likumal Punjabi & Ors

The Supreme Court addressed the legality of the Bombay High Court's judgment regarding the forfeiture of property under Section 7 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 (SAFEMA). The Court held that the High Court erred in applying the first proviso to Clause (b) of sub-section (2) of Section 2 of SAFEMA, as the revocation of detention orders under Section 11(1)(b) of the Conservation of Foreign Exchange and Prevention of Smuggling Activities Act (COFEPOSA) did not invalidate the forfeiture proceedings initiated while the detention was in effect. The appeal by the Union of India was allowed, reinstating the forfeiture order.