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Supreme Court of India 2023-03-22 dismissed

M/S. PLATINUM THEATRE AND OTHERS vs COMPETENT AUTHORITY SMUGGLERS &

Bench: 2 — Ajay Rastogi, Bela M. Trivedi

In Brief

M/s. Platinum Theatre, a partnership firm, challenged the forfeiture of its property under the Smugglers and Foreign Exchange Manipulators (Forfeiture of Property) Act, 1976. One partner had been detained under anti-smuggling laws. The appellants argued that the land was privately owned and that they should have been offered a fine option since disclosed sources exceeded 50% of construction costs. The Supreme Court upheld forfeiture, holding that appellants failed to prove sources of funds under Section 8's burden of proof. Since the majority of the investment (exceeding 50%) remained unexplained, Section 9 relief (fine option) did not apply. The Court also rejected delay arguments, finding proceedings were continuous from 1977 onwards. Forfeiture was proper and lawful.

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Administrative Law Forfeiture of Property Smuggling and Foreign Exchange Burden of Proof Illegally Acquired Property Criminal Procedure Constitutional Law

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