Introduction

The Supreme Court in Mangilal v. State of Madhya Pradesh set aside a conviction under Sections 8(b) and 15(c) of the NDPS Act, 1985. The Court held that non-compliance with Section 52A (procedure for inventory, certification, and disposal of seized narcotics) is fatal to the prosecution’s case.

Facts of the Case

• Mangilal was accused of possessing 98 kg of poppy husk.
• The trial court convicted him under Sections 8(b) & 15(c), sentencing him to 10 years RI + fine.
• The conviction was upheld by the Madhya Pradesh High Court.
• Before the Supreme Court, Mangilal argued that mandatory safeguards under Section 52A were not followed.

Issues

• Whether non-compliance with Section 52A NDPS Act vitiates the conviction?
• Can reliance solely on oral testimony of police officials sustain conviction without certified inventory/chain of custody?
• Did the lower courts err in upholding conviction despite serious procedural lapses?

 Petitioner’s Arguments

• No compliance with Section 52A (no Magistrate certification, no proper inventory, no valid samples).
• Conviction rested only on police testimony, with no independent corroboration.
• This violates the fair trial guarantee under Article 21 of the Constitution.

 Respondent’s Arguments

• Contraband was lawfully seized and recovery was proved.
• Minor procedural lapses should not override substantive proof.
• Police testimony is credible and sufficient in narcotics cases.

Judgment

The Supreme Court acquitted Mangilal, holding that:

• Section 52A is mandatory; failure to comply renders the case unsustainable.
• No Magistrate’s certification, no inventory, and non-production of seized material fatally undermined the prosecution.
• Sole reliance on police testimony is insufficient in serious penal cases.

Conclusion

The Court reaffirmed that procedural safeguards under NDPS Act are not optional. Strict compliance with Section 52A is necessary to ensure fairness and protect against misuse. Since the prosecution failed to establish integrity of the seized narcotics, Mangilal’s conviction was set aside.