SURESH NANDA versus C.B.I

SURESH NANDA versus C.B.I

Impounding of a passport, although the police may seize it during investigation, can only be effected by the passport authority per Passports Act, 1967. Section 104 CrPC is a general provision and cannot override specific provisions of the Passports Act regarding impounding of passports; thus, retention of the passport by the CBI was illegal.

Parties
Appellant: Suresh Nanda; Respondent: C.B.I.
Jurisdiction
India
Judgment Date
24 January 2008
Procedural Posture
Criminal Appeal / Appeal Against High Court Order
Outcome
Appeal allowed
Legal Topics
Impounding of Passport, Special Law Vs General Law, Jurisdiction Over Passport Seizure, Interpretation of Statutes, Right to Travel Abroad

Case Brief

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Parties

Suresh Nanda

Appellant

C.B.I.

Respondent

Procedural Posture

Criminal Appeal / Appeal Against High Court Order

  1. 1 Whether CBI can retain or impound a passport seized during search under orders of court
  2. 2 Whether the power to impound a passport vests only in passport authority under Passports Act, 1967
  3. 3 Whether Section 104 CrPC applies to impound passport, or does Passports Act, 1967 prevail

Ratio Decidendi

Impounding of a passport, although the police may seize it during investigation, can only be effected by the passport authority per Passports Act, 1967. Section 104 CrPC is a general provision and cannot override specific provisions of the Passports Act regarding impounding of passports; thus, retention of the passport by the CBI was illegal.

Court Disposition

Appeal allowed

Orders

  • Order of High Court set aside
  • Respondent directed to hand over passport to appellant within a week