New Delhi, March 1: The Supreme Court today set aside an order passed by the Allahabad High Court directing the Narcotics Control Bureau (NCB) Director to pay Rs 5 lakh compensation to a man who was allegedly wrongfully confined, observing that the High Court had overstepped its jurisdiction.
A bench comprising Justices Sanjay Karol and Manmohan termed the High Court’s decision to grant compensation as "without the authority of law," highlighting that such judicial overreach cannot be endorsed.
Background of the Case
The case originated from a joint operation by the Narcotics Control Bureau, in which officers seized 1,280 grams of a brown powder suspected to be heroin from two individuals, Man Singh Verma and Aman Singh. Subsequently, Verma was charged under Sections 8(C), 21, and 29 of the Narcotic Drugs and Psychotropic Substances (NDPS) Act, 1985, and remanded to judicial custody.During custody, Verma approached the Special Judge (NDPS) in Barabanki District for bail, which was initially rejected. He then appealed to the Lucknow bench of the Allahabad High Court.
Laboratory Findings Lead to Release
On January 30, 2023, initial laboratory results revealed that the seized substance did not contain heroin or any other narcotics. A second analysis conducted by the Central Forensic Science Laboratory (CFSL), Chandigarh, confirmed these findings on April 5, 2023, affirming the absence of narcotics in the samples tested.Following these conclusive lab reports, the NCB filed a closure report before the Special NDPS Court, leading to Verma’s release from the Barabanki District Jail.
Allahabad HC Orders Compensation Despite Release
Despite Verma's release and the filing of the closure report, the Allahabad High Court continued adjudicating his pending bail application. It observed that Verma, being young, had been wrongfully confined for approximately four months, even after the initial laboratory report showed negative results. Consequently, the High Court directed the NCB Director to compensate Verma with Rs 5 lakh.Supreme Court’s Observations
Criticizing the High Court’s directive, the Supreme Court noted, "Time and again, the act of courts overstepping the bounds of jurisdiction has clearly been frowned upon. The instant case is another such example." The apex court clarified that since Verma had already been released, the bail application before the High Court had become redundant and should have simply been dismissed.The bench further remarked, "No occasion arose for the court to pass an order delving into the aspects of impermissibility of retesting and/or wrongful confinement." Emphasizing procedural correctness, the court stated that the High Court’s exercise of jurisdiction in an already infructuous matter was both unjustified and legally erroneous.
While acknowledging that wrongful restriction of liberty without proper legal procedures is a serious violation of rights, the Supreme Court underscored that legal remedies available in such situations must be pursued strictly within the prescribed legal framework.
With this ruling, the Supreme Court reiterates the necessity of judicial restraint, ensuring courts act strictly within their jurisdictional limits.
