The Supreme Court has ruled that Interim Vehicle RC Custody disputes cannot be decided solely on the basis of a vehicle’s registration certificate. Instead, courts must examine the complete factual background before granting interim custody under Sections 451 and 457 of the Code of Criminal Procedure (CrPC). The judgment makes it clear that registration remains an important piece of evidence, but it does not automatically determine who should receive temporary possession of a seized vehicle.
A Bench comprising Justice Sanjay Karol and Justice Augustine George Masih dismissed an appeal filed by a company director seeking interim custody of five commercial vehicles. These vehicles included a Bolero pick-up, three excavators, and a tipper truck. Although the registration certificates stood in the appellant’s company’s name, the Court held that criminal courts must consider several practical factors before granting interim custody.
Registration Certificate Is Only Evidence
Justice Augustine George Masih explained that Sections 451 and 457 CrPC give courts discretionary power to decide interim possession through a prima facie assessment. Therefore, judges must determine which party should temporarily retain custody until the dispute reaches its final conclusion.
Moreover, the Bench clarified that the decision in Sunderbhai Ambalal Desai v. State of Gujarat does not create a mandatory rule requiring courts to hand over seized vehicles to the registered owner in every case. Instead, the judgment encourages courts to release seized property promptly so that it does not lose value.
The Court observed:
“Registration is a relevant factor, but it is evidentiary and not conclusive of entitlement to interim possession.”
According to the Bench, criminal courts grant temporary possession only to preserve the property. They do not decide ownership or title during interim proceedings.
Corporate Dispute Led to Criminal Proceedings
The dispute arose between Krishnan Narayana, a director of M/s Pure Minerals, and M/s Earth Stein Private Limited. Narayana previously held an 80% stake in Earth Stein before disagreements emerged.
Narayana lodged criminal complaints alleging that Earth Stein’s management illegally entered his premises and removed five commercial vehicles registered in Pure Minerals’ name. However, Earth Stein filed counter-complaints. The company alleged that Narayana diverted more than ₹1.73 crore from its corporate funds to purchase those vehicles under another company’s name.
Police later seized the vehicles. Both parties requested interim custody before the trial court. Initially, the trial court rejected both applications. However, the Andhra Pradesh High Court later granted interim custody to Earth Stein.
Supreme Court Preferred Practical Possession
The Supreme Court agreed with the High Court after examining the surrounding circumstances. First, police seized the vehicles from Earth Stein’s mining sites, where the company actively used them. Second, Earth Stein had continuously paid the loan installments through its own bank accounts. Finally, the Court noted the existence of a written undertaking that permitted Earth Stein to operate the vehicles until both companies reconciled their accounts.
Consequently, these facts carried greater weight than the registration certificates while deciding Interim Vehicle RC Custody.
Interim Custody Does Not Decide Ownership
Finally, the Supreme Court emphasized that its order concerns only interim possession under criminal procedure. It does not determine ownership, civil title, or the validity of disputed corporate transactions.
As a result, the Court confirmed that criminal courts should adopt a holistic approach while deciding interim custody applications. Registration certificates remain relevant evidence. Nevertheless, courts must also evaluate operational possession, financial responsibility, and other surrounding circumstances before granting temporary custody of seized vehicles.
