The Supreme Court has ruled that a vehicle's registration certificate, by itself, does not automatically determine who should receive interim custody of seized property during pending criminal proceedings. Dismissing appeals filed by Krishnan Narayana, the Court held that while registration is an important factor, courts must examine the overall circumstances before deciding who is entitled to temporary possession.
A Bench of Justice Sanjay Karol and Justice Augustine George Masih delivered the judgment on July 27, 2026, affirming the Andhra Pradesh High Court's decision to grant interim custody of the disputed vehicles to M/s Earth Stein Private Limited.
Background of the Case
The dispute arose from the seizure of five vehicles a Bolero City Pick-up, three excavators, and an Ashok Leyland tipper during the investigation of criminal cases involving the appellant and the respondent company. The appellant claimed that the vehicles belonged to his company, M/s Pure Minerals, and alleged that they had been forcibly taken away after disputes relating to business affairs.
On the other hand, the respondent company alleged that company funds had been misused to purchase the vehicles in the name of the appellant's company. Separate criminal proceedings concerning these allegations remain pending before the competent court.
After the vehicles were seized by the police, both sides sought interim custody before the trial court. When their respective applications were rejected, they approached the Andhra Pradesh High Court. The High Court ultimately directed that interim custody be handed over to the respondent company, prompting the present appeals before the Supreme Court.
Arguments Before the Supreme Court
The appellant argued that since the registration certificates stood in the name of his company, he was entitled to interim custody under Sections 451 and 457 of the Code of Criminal Procedure. Reliance was placed on the Supreme Court's earlier decision in Sunder Bhai Ambalal Desai v. State of Gujarat, contending that seized vehicles should ordinarily be released to the registered owner pending trial.
The respondent company opposed the plea, stating that the vehicles had remained in its possession and operational use. It further argued that the appellant had voluntarily executed an undertaking permitting the company to continue using the machinery until settlement of accounts and that the loan instalments for the vehicles had been paid from the company's account.
Court's Observations
Examining Sections 451 and 457 CrPC, the Supreme Court observed that these provisions empower courts to decide who should receive interim custody based on the circumstances of each case. The Court clarified that such proceedings are not intended to determine ownership but only to identify the person best entitled to temporary possession until the dispute is finally decided.
The Bench observed:
“The Court does not adjudicate title but merely undertakes the exercise of granting interim possession.”
The Court further explained that the objective of these provisions is to ensure that seized property does not deteriorate while criminal proceedings remain pending.
Rejecting the appellant's principal argument, the Bench said the earlier Sunder Bhai Ambalal Desai judgment does not create an inflexible rule requiring courts to always release seized vehicles to the registered owner.
As the judgment states:
“Registration is a relevant factor, but it is evidentiary and not conclusive of entitlement to interim possession.”
The Court noted several circumstances favouring the respondent company, including the continued possession of the vehicles, the appellant's written undertaking allowing their continued operation, and the admitted payment of loan instalments by the respondent company. It also observed that disputes relating to the appellant's resignation, share transfer, and allegations of forgery require evidence and must be decided in separate proceedings rather than during an application for interim custody.
Supreme Court's Decision
After considering the material on record, the Supreme Court concluded that the circumstances supporting the respondent company's claim outweighed the fact that the registration certificates stood in the appellant's company's name.
Accordingly, the Court upheld the Andhra Pradesh High Court's order granting interim custody of the vehicles to M/s Earth Stein Private Limited and dismissed the appeals.
The Bench clarified that its findings are confined solely to the issue of interim custody and should not be treated as deciding the pending disputes concerning ownership, alleged misappropriation, resignation, or share transfer, which will be determined independently in the appropriate proceedings.
Case Details
Case Title: Krishnan Narayana v. State of Andhra Pradesh & Ors. Etc.
Case Number: Criminal Appeal Nos. of 2026 (@ SLP (Criminal) Nos. 19205-06 of 2025)
Judge: Justice Sanjay Karol and Justice Augustine George Masih
Decision Date: July 27, 2026
