UNION OF INDIA vs MOHANLAL LIKUMAL PUNJABI .

The Supreme Court examined the legality of the Bombay High Court's judgment which held that the order of forfeiture under Section 7 of the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976 (SAFEMA) was unsustainable. The Court clarified that the first proviso to Clause (b) of sub-section (2) of Section 2 of SAFEMA did not apply, 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 force. The Court upheld the forfeiture order, emphasizing the validity of the proceedings initiated under SAFEMA.