AUTOMOBILE PRODUCTS INDIA LTD. vs DAS JOHN PETER .

The Supreme Court addressed the dismissal of a criminal complaint under Section 406 IPC and Section 630 of the Companies Act, 1956, holding that the trial court's reliance solely on Section 630 was erroneous. The Court emphasized that the accused, having retired, was obligated to return possession of the property to the company, and his failure to do so constituted an offense under both statutes. The Court set aside the lower court's order and directed that the complaint be reinstated for further proceedings.