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Supreme Court of India 2021-10-06

BHARATH BOOSHAN AGGARWAL vs STATE OF KERALA

Bench: 2 — Indira Banerjee, S. Ravindra Bhat

In Brief

The appellant, a sandalwood oil manufacturer and trader, was convicted under Section 27(1)(d) of the Kerala Forest Act for possession of forest produce allegedly illegally removed from a reserved forest. The trial court convicted him; the Sessions Court acquitted him; and the High Court reversed the acquittal. The Supreme Court held that sandalwood oil is forest produce, but Section 27(1)(d) requires proof that the accused 'knowingly' possessed illicitly-removed produce. Section 69's presumption concerns ownership, not the accused's state of mind. Mere seizure and lack of transit documentation do not establish the necessary mens rea. The prosecution failed to prove beyond reasonable doubt that the goods were illicitly procured or that the accused knew of any illicit origin. The Court set aside the High Court's judgment and allowed the appeal, restoring the acquittal.", <parameter name="disposition">allowed

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Criminal Law Forest Conservation Mens Rea Presumption of Innocence Burden of Proof Appellate Review

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