{"id":138327,"date":"1960-10-03T00:00:00","date_gmt":"1960-10-02T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/amba-lal-vs-the-union-of-india-and-others-on-3-october-1960"},"modified":"2015-01-30T15:22:25","modified_gmt":"2015-01-30T09:52:25","slug":"amba-lal-vs-the-union-of-india-and-others-on-3-october-1960","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/amba-lal-vs-the-union-of-india-and-others-on-3-october-1960","title":{"rendered":"Amba Lal vs The Union Of India And Others on 3 October, 1960"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Amba Lal vs The Union Of India And Others on 3 October, 1960<\/div>\n
Equivalent citations: 1961 AIR 264, \t\t 1961 SCR (1) 933<\/div>\n
Author: K Subbarao<\/div>\n
Bench: Sinha, Bhuvneshwar P.(Cj), Kapur, J.L., Gajendragadkar, P.B., Subbarao, K., Wanchoo, K.N.<\/div>\n
           PETITIONER:\nAMBA LAL\n\n\tVs.\n\nRESPONDENT:\nTHE UNION OF INDIA AND OTHERS.\n\nDATE OF JUDGMENT:\n03\/10\/1960\n\nBENCH:\nSUBBARAO, K.\nBENCH:\nSUBBARAO, K.\nSINHA, BHUVNESHWAR P.(CJ)\nKAPUR, J.L.\nGAJENDRAGADKAR, P.B.\nWANCHOO, K.N.\n\nCITATION:\n 1961 AIR  264\t\t  1961 SCR  (1) 933\n CITATOR INFO :\n RF\t    1971 SC  44\t (38)\n D\t    1974 SC 859\t (29,41,44)\n D\t    1975 SC2288\t (13)\n\n\nACT:\n Evidence--Customs authorities recovering articles  suspected\n to  have  been smuggled--Accused pleading  articles  brought\n from Pakistan at time of Partition--Burden of proof--Imports\n Exports  Control  Act, 1947(10 of 1947), s.  3--Sea  Customs\n Act, 1878 (8 of 1878) ss. 19, 167(8) and 178-A--Land Customs\n Act,  1924 (19 of 1924), ss. 5 and 7--Indian  Evidence\t Act,\n 1872 (1 of 1872), s. 106.\n 934\n\n\n\nHEADNOTE:\n The  appellants house was searched on June 22, 1951, by  the\n Customs   authorities\tand  ten  articles   were   recovered\n therefrom.    In  the\tinquiry\t before\t the  Collector\t  the\n appellant  stated  that  the first five  articles  had\t been\n brought  by  him in 1947 from Pakistan\t after-partition  and\n that with respect to the other five articles he   was a bona\n fide  purchaser  thereof.   The  Collector  held  that\t  the\n appellant had failed to establish his case and held that the\n goods\twere  imported into India in contravention Of  S.  3,\n Import\t Export Control Act read with ss. 19 and 167(8),  Sea\n Customs Act and ss. 4 and 5 Land Customs Act read with S.  7\n thereof.  This decision was upheld on appeal by the  Central\n Board of Revenue and by the Central Government on  revision.\n The  appellant contended that: (i) the onus of proving\t that\n the  first  five  articles were smuggled goods\t was  on  the\n department which it had failed to discharge, and (2) even if\n the  other  five articles which he purchased  were  smuggled\n goods he was not concerned with their importation.\n Held, that the onus was on the authorities to establish that\n the first five articles were imported into India after March\n 1948, when the customs barrier was put up for the first time\n between India and Pakistan, and that the authorities  having\n failed\t to  adduce  any  evidence to  prove  this  fact  the\n appellant  could not be held guilty of any of\tthe  offences\n charged.   The onus did not shift by virtue Of S. 178A,  Sea\n Customs Act or s. 5, Land Customs Act, as the former section\n was  not  in operation at the relevant time and  the  latter\n section  was not applicable to the facts of this case ;  nor\n did  the  onus shift by virtue of s. 106, Evidence  Act,  as\n that  section\tcould  not  be used  to\t undermine  the\t well\n established rule that the burden was on the prosecution  and\n never shifted.\n Shambu Nath Mehra v. The State of Ajmer,<\/a> [1956] S.C.R.\t 199,\n followed.\n With  respect\tto  the\t other\tfive  articles\teven  if  the\n appellant  was\t right\tin his contention  that\t he  was  not\n concerned in their importation he was liable to the  penalty\n under\ts. 7(1)(c), Land Customs Act, 1924, for\t keeping  the\n articles knowing them to be smuggled goods.\n\n\n\nJUDGMENT:\n<\/pre>\n
 CIVIL APPELLATE JURISDICTION: Civil Appeal No. 153 of 1956.
\n Appeal\t from the judgment and order dated November 3,\t1954,
\n of  the Punjab High Court in Civil Writ No. 253-D  of\t1954.
\n Veda Vyasa, S. K. Kapur, K. K. Jain and Ganpat Rai, for  the
\n appellant.\n<\/p>\n
 H.  N. Sanyal, Additional Solicitor-General of India, H.  R.
\n Khanna and T. M. Sen, for the respondents.\n<\/p>\n
 935<\/span><\/p>\n
 1960.\tOctober 3. The Judgment of the Court was delivered by
\n SUBBA RAO J.-This appeal by certificate is directed  against
\n the  order of the High Court of Judicature of the  State  of
\n Punjab dismissing the petition filed by the appellant\tunder
\n Art. 226 of the Constitution.\n<\/p>\n
 The facts giving rise to this appeal may be briefly  stated.
\n The  appellant\t is at present a resident of  Barmer  in  the
\n State\tof  Rajasthan.\tBut before 1947 he was\tliving\tin  a
\n place\twhich  is  now in Pakistan.  On June  22,  1951,  the
\n Deputy\t  Superintendent,  Land\t Castoms   Station,   Barmer,
\n conducted  a search of the appellant’s house  and  recovered
\n therefrom the following ten articles :\n<\/p>\n
 ————————————————————\n<\/p>\n
 Articles seized.      Weight\t\tEstimated\n\t\t\t\t\tvalue.\n<\/pre>\n
 ————————————————————\n<\/p>\n
\t\t\t\t\t   Rs.\n<\/p><\/blockquote>\n
 1. Silver slab.      2600 tolas\t 5,200\/-\n 2. 29 Sovereigns\t\t\t 2,262\/-\n   (King Ed. VII).\n 3. 9 pieces of gold\n    bullion\t       201 tolas\n\t\t       and 9 mashas.   22,193\/-\n 4. 4 pieces of silver\n    bullion\t       114 tolas.\t 230\/-\n 5. Uncurrent silver\n    coins  numbering   575.\t\t  865\/-\n 6. Gold bars.\t\t49 tolas and\n\t\t\t 9 mashas    5,475\/-\n 7. 255 Phials of liquid\n  gold.\t\t\t\t\t9,875\/-\n 8. Torches 23.\n 9. Playing cards 3 Dozens\n\t\t\t\t\t  400\/-\n 10.Glass beads 48 packets.\n\t\t\t\t       -------\n\t\t\t     Total... 46,500\/-\n<\/pre>\n
 ————————————————————
\n On  July  14,\t1951 the  Assistant  Collector,\t Ajmer,\t gave
\n notice’  to the appellant to show cause and explain why  the
\n goods\tseized\tfrom him should not be confiscated  under  s.
\n 167(8)\t of the Sea Customs Act and s. 7 of the Land  Customs
\n Act.  The appellant in his reply
\n 936<\/span>
\n stated\t that  items  to 5 supra were  brought\tby  him\t from
\n Pakistan after the partition of the country in 1947 and that
\n items\t6 to 10 were purchased by him bonafide for  value  in
\n Barmer.  On October 27, 1951, the appellant appeared  before
\n the  Collector of Central Excise, who made an\tenquiry,  and
\n admitted  before him that items 6 to 10 were smuggled\tgoods
\n from Pakistan, but in regard to the other items be  reitera-
\n ted  his plea that he originally brought them from  Pakistan
\n in the year 1947.  The Collector of Central Excise held that
\n the appellant bad failed to establish that items 1 to 5  had
\n been  brought by him to India in the year 1947 and  he\t also
\n did not accept the plea of the appellant in regard to\titems
\n 6  to 10 that he was a bonafide purchaser of them.   In  the
\n result\t he held that all the goods were imported into\tIndia
\n in  contravention of, (i) s. 3 of the Import Export  Control
\n Act read with ss. 19 and 167(8) of the Sea Customs Act, (ii)
\n ss. 4 and 5 of the Land Customs Act read with s. 7  thereof.
\n He made an order of confiscation of the said articles\tunder
\n s.  167(8)  of\t the Sea Customs Act and s.  7\tof  the\t Land
\n Customs Act; but under s.     183 of the Sea Customs Act  he
\n gave him an option to\t  redeem the confiscated goods within
\n four months of the date of the order on payment of a sum  of
\n Rs.  25,000.  In addition he imposed a penalty of Rs.\t1,000
\n and directed the payment of import duty leviable on all  the
\n items\ttogether  with other charges before  the  goods\t were
\n taken out of customs control.\tAggrieved by the said  order,
\n the  appellant preferred an appeal to the Central  Board  of
\n Revenue.   The\t Central  Board of Revenue  agreed  with  the
\n Collector  of\tCentral Excise that the onus of\t proving  the
\n import\t of the goods in question was on the  appellant.   In
\n regard\t to  items  1  to 5, it\t rejected  the\tplea  of  the
\n appellant mainly on the basis of a statement alleged to have
\n been  made  by\t him  at the time  of  seizure\tof  the\t said
\n articles.   In\t the result the appeal\twas  dismissed.\t  The
\n revision  filed by the appellant to the  Central  Government
\n was  also  dismissed  on August 28,  1953.   Thereafter  the
\n appellant  filed  a  writ petition under  Art.\t 226  of  the
\n Constitution in the High Court
\n 937<\/span>
\n of  Punjab but it was dismissed by a division bench  of  the
\n High Court on November 3, 1954.  Hence this appeal.
\n It  would  be\tconvenient to deal with this  appeal  in  two
\n parts-one in regard to items 1 to 5 and the other in  regard
\n to items 6 to 10.\n<\/p>\n
 The  decision in regard to items 1 to 5 turns purely on  the
\n question  of onus.  The Collector of Central Excise as\t well
\n as  the  Central  Board of Revenue held  that\tthe  onus  of
\n proving the import of the goods lay on the appellant.\tThere
\n is  no\t evidence  adduced  by\tthe  customs  authorities  to
\n establish  the\t offence of the appellant, namely,  that  the
\n goods\twere  smuggled into India after the  raising  of  the
\n customs barrier against Pakistan in March 1948.  So too,  on
\n the part of the appellant, except his statement made at  the
\n time  of  seizure of the goods and also at the time  of  the
\n inquiry that he brought them with him into India in 1947, no
\n other\t acceptable  evidence  has  been  adduced.   In\t  the
\n circumstances,\t the question of onus of proof\tbecomes\t very
\n important  and the decision turns upon the question on\t whom
\n the burden of proof lies.\n<\/p>\n
 This Court has held that a customs officer is not a judicial
\n tribunal  and\tthat  a\t proceeding  before  him  is  not   a
\n prosecution.\tBut  it cannot be denied that  this  relevant
\n provisions  of the Sea Customs Act and the Land Customs  Act
\n are  penal in character.  The appropriate customs  authority
\n is  empowered\tto make an inquiry in respect of  an  offence
\n alleged  to have been committed by a person under  the\t said
\n Acts,\tsummon\tand  examine  witnesses,  decide  whether  an
\n offence  is committed, make an order of confiscation of  the
\n goods\tin  respect  of which the offence  is  committed  and
\n impose\t penalty  on the person concerned ; see ss.  168  and
\n 171A  of  the Sea Customs Act and ss. 5 and 7\tof  the\t Land
\n Customs Act.  To such a situation, though the provisions  of
\n the  Code of Criminal Procedure or the Evidence Act may  not
\n apply\texcept\tin  so\tfar  as\t they  are  statutorily\t made
\n applicable,   the   fundamental   principles\tof   criminal
\n jurisprudence and of natural justice must necessarily apply.
\n If so, the burden of proof is on the customs authorities and
\n they have to
\n 938<\/span>
\n bring home the guilt to the person alleged to have committed
\n a  particular\toffence\t under\tthe  said  Acts\t by  adducing
\n satisfactory evidence.\t In the present case no such evidence
\n is  forthcoming;  indeed there is no tittle of\t evidence  to
\n prove\tthe case of the customs authorities.  But it is\t said
\n that  the onus shifted to the appellant for  three  reasons,
\n namely,  (i) by reason of the provisions of s. 178A  of  the
\n Sea Customs Act; (ii) by reason of s. 5 of the Land  Customs
\n Act; and (iii) by reason of s. 106 of the Evidence Act.
\n Section  178A\tof the Sea Customs Act does  not  govern  the
\n present  case, for that section was inserted in that Act  by
\n Act No. XXI of 1955 whereas the order of confiscation of the
\n goods in question was made on January 18, 1952.  The section
\n is  prospective  in  operation and cannot  govern  the\t said
\n order.\n<\/p>\n
 Nor  does s. 5 of the Land Customs Act apply to the  present
\n case.\tUnder s. 5(1) of the said Act, “Every person desiring
\n to  pass  any\tgoods by land, out of  or  into\t any  foreign
\n territory  shall  apply  in writing for  a  permit  for  the
\n passage  thereof, to the Land Customs Officer incharge of  a
\n land customs Station By sub-s. (2) of s. 5 of the said\t Act,
\n if  the requisite duty has been paid or the goods have\t been
\n found\tby the Land Customs Officer to be free of  duty,  the
\n Land Customs Officer is empowered to grant a permit.\tUnder
\n sub-s.\t (3)  thereof,\t”  Any\tLand  Customs  Officer,\t duly
\n empowered by the Chief Customs authority in this behalf, may
\n require any person in charge of any goods which such Officer
\n has reason to believe to have been imported, or to be\tabout
\n to  be exported, by land from, or to, any foreign  territory
\n to  produce the permit granted for such goods; and any\t such
\n goods\twhich are dutiable and which are unaccompanied\tby  a
\n permit or do not correspond with the specification contained
\n in  the  permit  produced, shall be detained  and  shall  be
\n liable to confiscation.” This section has no bearing on  the
\n question  of onus of proof.  This section obviously  applies
\n to a case where a permit is required for importing goods  by
\n land  from a foreign country into India and it empowers  the
\n Land Customs Officer, who has reason to believe that any
\n 939<\/span>
\n goods have been imported by land from any foreign territory,
\n to  demand  the permit and to verify whether  the  goods  so
\n imported correspond with the specification contained in  the
\n permit.   If  there was no permit or if the  goods  did  Dot
\n correspond  with the specification contained in the  permit,
\n the   said  goods  would  be  liable  to  be  detained\t  and
\n confiscated.  The application of this section is conditioned
\n by  the legal requirement to obtain a permit.\tIf no  permit
\n is  necessary to import goods into India, the provisions  of
\n the  section cannot be attracted.  In the present  case  the
\n customs  barrier was established only in March,  1948,\t that
\n is,  after the said items of goods are stated by the  appel-
\n lant to have been brought into India.\n<\/p>\n
 We  cannot also accept the contention that by reason of  the
\n provisions  of s. 106 of the Evidence Act the onus  lies  on
\n the  appellant\t to prove that he brought the said  items  of
\n goods\tinto India in 1947.  Section 106 of the Evidence  Act
\n in terms does not apply to a proceeding under the said Acts.
\n But it may be assumed that the principle underlying the said
\n section  is of universal application.\tUnder  that  section,
\n when  any  fact is especially within the  knowledge  of  any
\n person,  the burden of proving that fact is upon him.\t This
\n Court in Shambu Nath Mehra v. The State of Ajmer<\/a> (1),\tafter
\n considering  the  earlier  Privy Council  decisions  on  the
\n interpretation of s. 106 of the Evidence Act, observed at p.
\n 204 thus:\n<\/p>\n
\t       “The  section cannot be used to undermine  the
\n\t       well  established rule of law that, save in  a
\n\t       very exceptional class of case, the burden  is
\n\t       on the prosecution and never shifts.”\n<\/p><\/blockquote>\n
 If s. 106 of the Evidence Act is applied, then, by  analogy,
\n the  fundamental principles of criminal  jurisprudence\t must
\n equally  be  invoked.\tIf so, it follows that\tthe  onus  to
\n prove\tthe  case  against the appellant is  on\t the  customs
\n authorities  and  they failed to discharge  that  burden  in
\n respect of items 1 to 5. The order of confiscation  relating
\n to items 1 to 5 is set aside.\n<\/p>\n
 Before\t closing this aspect of the case,  some\t observations
\n have to be made in respect of the manner in
\n (1)  [1956] S.C.R. 199.\n<\/p>\n
 940<\/span><\/p>\n
 which\tthe statement given by the appellant when  the\tgoods
\n were seized was used against him by the customs authorities.
\n It would be seen from the order of the Collector of  Central
\n Excise as well as that of the Central Board of Revenue\t that
\n they had relied upon the statement alleged to have been made
\n by him at the time the search was made in his house in order
\n to  reject  his case that he brought some of  the  items  of
\n goods\tinto  India in the year 1947.  The appellant  in  his
\n reply to the show-cause notice complained that his statement
\n was taken in English, that he did not know what was recorded
\n and that his application for inspection and for the grant of
\n a copy of his statement was not granted to him.  It does not
\n appear\t from  the records that he was given a\tcopy  of  the
\n statement  or that he was allowed to inspect the  same.   In
\n the  circumstances  we\t must  point  out  that\t the  customs
\n authorities were not justified to rely upon certain, alleged
\n discrepancies\tin that statement to reject  the  appellant’s
\n subsequent  version.\tIf they wanted to rely upon  it\t they
\n should\t have  given  an, opportunity  to  the\tappellant  to
\n inspect it and, at any rate, should have supplied him a copy
\n thereof.\n<\/p>\n
 Coming to items 6 to 10, we have no reason to reject, as  we
\n have  been asked to do, the statement made in the  order  of
\n the Collector of Central Excise dated October 27, 1951, that
\n the  appellant\t accepted that items 6 to  10  were  smuggled
\n goods\tfrom  Pakistan.\t  It would have been  better  if  the
\n customs authorities had taken that admission in writing from
\n the appellant, for that would prevent the retraction of  the
\n concession  on\t second\t thoughts.  That apart,\t it  is\t more
\n satisfactory if a body entrusted with functions such as  the
\n customs authorities are entrusted with takes that precaution
\n when  its decision is mainly to depend upon such  admission.
\n But in this case, having regard to the circumstances  under,
\n and  the manner in, which the said concession was  made,  we
\n have no reason to doubt the correctness of the statements of
\n fact  in  regard to this matter made in the  orders  of  the
\n customs authorities.  If so, it follows that the finding  of
\n the  customs  authorities that the appellant  purchased  the
\n said items, which were smuggled goods, should
\n 941<\/span>
\n prevail.   The\t order of confiscation of  these  five\titems
\n will, therefore, stand.\n<\/p>\n
 Even  so,  it is contended by the learned  counsel  for  the
\n appellant  that  the  customs\tauthorities  went  wrong   in
\n imposing a penalty on him under s. 167(8) of the Sea Customs
\n Act.  The said section reads:\n<\/p>\n
 ”  If any goods, the importation or exportation of which  is
\n for  the  time being prohibited or restricted\tby  or\tunder
\n Chapter  IV of this Act, be imported into or  exported\t from
\n India\t    contrary\t to\tsuch\t  prohibition\t   or
\n restriction…………  such goods shall be liable to\t con-
\n fiscation; and
\n any person concerned in any such offence shall be liable  to
\n a penalty not exceeding three times the value of the  goods,
\n or not exceeding one thousand rupees.”\n<\/p>\n
 The  appellant’s  argument is that though he  purchased  the
\n said smuggled goods he is not concerned with the importation
\n of  the  goods contrary to the\t prohibition  or  restriction
\n imposed  by  or under Ch.  IV of the Sea Customs  Act.\t  The
\n ‘offence  consists  in importing the goods contrary  to  the
\n prohibition and, therefore, the argument proceeds, a person,
\n who has purchased them only after they were imported, is not
\n hit  by  the  said section.  There is\tsome  force  in\t this
\n argument, but we do not propose to express our final view on
\n the  matter as the appellant is liable to the penalty\tunder
\n s. 7(1)(c) of the Land Customs Act, 1924.  The said  section
\n reads:\n<\/p>\n
 ” Section 7 (1): Any person who-\n<\/p>\n
 (c)aids  in so passing or conveying any goods,\t or,  knowing
\n that  any  goods have been so passed or conveyed,  keeps  or
\n conceals such goods, or permits or procures them to be\t kept
\n or concealed,
\n shall be liable to a penalty not exceeding, where the\tgoods
\n are  not dutiable, fifty or, where the goods or any of\t them
\n are dutiable, one thousand rupees, and any dutiable goods in
\n respect  of  which the offence has been committed  shall  be
\n liable to confiscation.”\n<\/p>\n
 In this case the finding is that the appellant with the
\n     120<\/span>
\n 942<\/span>
\n knowledge  that the goods had been smuggled into India\t kept
\n the  goods, and, therefore, he was liable to  penalty\tunder
\n that section.\tWe hold that the penalty was rightly  imposed
\n on him.\n<\/p>\n
 It  is then contended that the Collector of  Central  Excise
\n had no jurisdiction to impose conditions for the release  of
\n the  confiscated goods.  The Collector of Central Excise  in
\n his  order says, ” In addition the import duty\t leviable  on
\n all these items together with other charges, if any payable,
\n should be paid and necessary formalities gone through before
\n the  goods can be passed out of Customs Control “. In\tShew.
\n pujanrai Indrasanrai Ltd. v. The Collector of Customs<\/a> (1), a
\n similar  question  arose for consideration  of\t this  Court.
\n There by an impugned order the Collector of Customs  imposed
\n two  conditions  for the release of the  confiscated  goods,
\n namely, (1) the production of a permit from the Reserve Bank
\n of India in respect of the gold within four months from  the
\n date  of  despatch of the impugned order, and (2)  the\t pay-
\n ment of proper customs duties and other charges leviable  in
\n respect  of the gold within the same period of four  months.
\n This  Court  held, agreeing with the High  Court,  that  the
\n Collector of Customs had no jurisdiction to impose the\t said
\n two  conditions.  The learned Additional  Solicitor  General
\n concedes that the said decision applies to the present case.
\n We do not, therefore, express any view whether that decision
\n can be distinguished in its application to the facts of  the
\n present  case.\t On the basis of the concession we hold\t that
\n the  conditions  extracted above, being severable  from  the
\n rest of the order, should be deleted from the said order  of
\n the Collector of Central Excise.\n<\/p>\n
 Learned  counsel  for\tthe appellant then  argues  that  the
\n option\t given in the said order to the appellant  to  redeem
\n the  confiscated  goods  for home  consumption\t within\t four
\n months of the order on payment of Rs. 25,000 was based\t upon
\n the  validity of the confiscation of all the ten items\t and,
\n as this Court now holds that confiscation was bad in respect
\n of items 1
\n (1)  [1959] S.C.R. 821.\n<\/p>\n
 943<\/span><\/p>\n
 to  5,\t the  amount  of the penalty  of  Rs.  25,000  should
\n proportionately be reduced.  There is justification for this
\n contention.   But we cannot reduce the amount, as  under  s.
\n 183 of the Sea Customs Act the amount has to be fixed by the
\n concerned officer as he thinks fit.  But as the basis of the
\n order partially disappears, we give liberty to the appellant
\n to apply to the customs authorities for giving him an option
\n to  redeem  the  confiscated goods on payment\tof  a  lesser
\n amount, having regard to the changed circumstances.
\n In  the result, the appeal is allowed in part and the\torder
\n of  the Collector of Central Excise is accordingly  modified
\n in  terms  of\tthe  finding given by  us.   As\t the  parties
\n succeeded  and\t failed in part, they are  directed  to\t bear
\n their own costs.\n<\/p>\n
\t\t       Appeal partly allowed.<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Amba Lal vs The Union Of India And Others on 3 October, 1960 Equivalent citations: 1961 AIR 264, 1961 SCR (1) 933 Author: K Subbarao Bench: Sinha, Bhuvneshwar P.(Cj), Kapur, J.L., Gajendragadkar, P.B., Subbarao, K., Wanchoo, K.N. PETITIONER: AMBA LAL Vs. RESPONDENT: THE UNION OF INDIA AND OTHERS. DATE OF JUDGMENT: […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-138327","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nAmba Lal vs The Union Of India And Others on 3 October, 1960 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/amba-lal-vs-the-union-of-india-and-others-on-3-october-1960\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Amba Lal vs The Union Of India And Others on 3 October, 1960 - 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