STATE OF M.P. vs MADHUKAR RAO

The Supreme Court addressed the question of whether a vehicle seized under Section 50(1)(c) of the Wild Life (Protection) Act, 1972 can be released by a Magistrate under Section 451 of the Code of Criminal Procedure, 1973. The Court held that the Magistrate has the authority to direct the release of the vehicle despite the State's claim that it became government property under Section 39(d) of the Act. The Court concluded that the provisions of the Wild Life Act do not preclude the exercise of powers under the Code, thereby allowing the release of the vehicle on Supurdnama.