Authority: Supreme Court of India, Criminal Appellate Jurisdiction

Order Date: 27 July 2026

Case Overview

  • Parties: Appellant – Krishnan Narayana (director of Pure Minerals); Respondent – Earth Stein Private Limited; also State of Andhra Pradesh and others as respondents.
  • Background: Vehicles (one Bolero City pick‑up, three excavators, one Ashok Leyland tipper) were purchased in the name of Pure Minerals between 2014‑2022. The appellant held 80 % shareholding in Earth Stein.
  • Allegations by appellant: On 31 May 2023 he was intimidated by S.R Kumar, T. Arivudainambi and G. Thirgunanam, forced to sign blank papers later used to forge his resignation on 16 June 2023; subsequent criminal trespass on 31 Aug 2023 led to seizure of the vehicles.
  • Counter‑allegations by respondent: appellant misappropriated ₹1,73,11,894 of company funds to purchase the vehicles; FIR No. 354/2023 filed under IPC 406.
  • Procedural history: FIR 353/2023 (crime‑trespass) filed 17 Sept 2023, closed as “mistake of fact” on 14 Aug 2024, reopened, chargesheet filed 9 Feb 2025; vehicles seized 7 Feb 2025. Separate FIR 102/2024 (intimidation/forgery) also closed as “mistake of fact”. Various criminal miscellaneous petitions filed in trial court (218/2025 by appellant, 384/2025 by respondent) were dismissed. High Court order dated 18 Sept 2025 granted interim custody of the vehicles to Earth Stein.
  • Points raised before the Supreme Court: appellant relied on Sunder Bhai Ambalal judgment asserting that registration certificate should dictate interim possession; argued resignation and undertaking were forged. Respondent argued resignation was voluntary, share‑transfer cheque encashed, undertaking genuine, EMI instalments on loan from Shriram Finance were paid by the company, and seizure was illegal.

Final Outcome

  • The Supreme Court held that interim custody under Sections 451 and 457 CrPC is a discretionary judicial function, not a determination of ownership.
  • Registration certificates are relevant but not conclusive; cumulative factors—possession at respondent’s operational site, written undertaking, and company‑paid EMI instalments—favor the respondent.
  • The Court affirmed the High Court’s order and granted interim possession of the Bolero pick‑up, three excavators and the Ashok Leyland tipper to Earth Stein Private Limited, subject to an undertaking affidavit.
  • Both appeals were dismissed as devoid of merit. The Court clarified that the observations are limited to interim custody and do not prejudice the pending ownership, misappropriation, or resignation disputes, which will be decided in separate proceedings.

Topics: Interim Custody, Criminal Procedure, Vehicle Seizure