Hira Singh vs Uoi

The Supreme Court referred several questions regarding the interpretation of the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act) to a three-judge bench, specifically questioning the validity of the precedent set in E. Micheal Raj v. Intelligence Officer, Narcotic Control Bureau (2008) 5 SCC 161. The court highlighted that the previous ruling may have overlooked critical provisions of the NDPS Act, particularly regarding the determination of punishment based on the total quantity of a mixture containing narcotic substances rather than just the content of the narcotic drug. The court's holding indicates a need for reconsideration of how mixed substances are treated under the NDPS Act, particularly in relation to Section 21.