In Brief
Narayan Das was convicted under Section 21(c) of the NDPS Act for possession of 236 vials of cough syrup containing Codeine Phosphate. The trial court sentenced him to 12 years' imprisonment; the High Court reduced it to 10 years (the statutory minimum), reasoning that no special factors under Section 32-B justified exceeding the minimum. The Supreme Court clarified that Section 32-B does not restrict sentencing discretion to its enumerated factors but preserves courts' broader authority to consider other relevant factors—notably, quantity of contraband—when imposing sentences above the minimum. The Court held the High Court had misinterpreted the statute. The petition was dismissed, but the legal error was corrected for future guidance.
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