In Brief
The respondent, Reliance Industries, was charged with evasion of excise duty under the Central Excises and Salt Act, 1944. The High Court discharged the accused on the ground that Rule 56A of the Central Excise Rules—which prescribed procedures for claiming credit—had been omitted without a saving clause, making the proceedings invalid. The Supreme Court allowed the appeal, holding that the omission of a procedural rule cannot vitiate a charge for the substantive offence of duty evasion. Evasion itself is an independent offence, and the prosecution retains the right to prove it regardless of procedural rule amendments.
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