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Supreme Court of India 2019-02-27 allowed

Department of Customs vs Sharad Gandhi

Bench: 2 — K.M. Joseph

In Brief

The Supreme Court held that prosecution under Sections 132 and 135 of the Customs Act, 1962 is not barred for offences involving unlawful export of antiquities, even though the Antiquities and Art Treasures Act, 1972 also regulates such export. The Court found that the two statutes can operate concurrently because they create distinct offences with different ingredients: the Customs Act requires false declaration or fraudulent evasion of prohibition, while the Antiquities Act requires unauthorized export. Section 4 of the Antiquities Act expressly applies the Customs Act except where inconsistent, and no such inconsistency exists here. The Court rejected the ejusdem generis reading of Section 30, finding that the legislature consciously provided for concurrent application. The appeal was allowed, overturning the High Court's discharge order.

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Customs Law Export Control Antiquities Law Cultural Heritage Criminal Procedure Double Jeopardy Statutory Interpretation Repugnancy Between Statutes Concurrent Offences

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