E. MICHEAL RAJ vs INTELLIGENCE OFFICER, NARCOTIC CTRL.BUR.

The Supreme Court upheld the conviction of the accused under Section 21(c) of the Narcotic Drugs and Psychotropic Substances Act, 1985, confirming that the substance in possession was a manufactured drug as defined under Section 2(xi) and Section 2(xvi) of the Act. The Court noted that the heroin found exceeded the threshold for a commercial quantity, thus justifying the application of Section 21. The accused was sentenced to a minimum of 10 years rigorous imprisonment and a fine of one lakh rupees, with the High Court's decision being affirmed.