The Supreme Court has ruled that a vehicle’s Registration Certificate (RC) should not be treated as the sole or decisive factor while deciding who should receive interim custody of a seized vehicle during the pendency of criminal proceedings. The Court clarified that although an RC is an important document, it is only one piece of evidence and cannot conclusively establish ownership in every situation.
Background of the Case
The dispute arose after a vehicle was seized during a criminal investigation. Competing claims were made over its interim custody, with one party relying primarily on the Registration Certificate to establish ownership.
The lower courts had largely focused on the name recorded in the RC while deciding the application for interim custody. The matter eventually reached the Supreme Court, which examined whether the registered owner’s name alone should determine who receives temporary possession of the vehicle until the trial concludes.
Supreme Court’s Observations
The Supreme Court observed that a Registration Certificate is not an inflexible or conclusive proof of ownership. While the document carries significant evidentiary value, courts must consider the complete facts and surrounding circumstances before granting interim custody.
The Bench explained that ownership may be supported by several forms of evidence, including:
- Sale agreements and transfer documents.
- Proof of payment.
- Possession and control of the vehicle.
- Insurance records.
- Other relevant documentary or factual evidence.
Therefore, a court should undertake a broader assessment rather than mechanically relying on the Registration Certificate alone.
Purpose of Interim Custody
The Court reiterated that the objective of granting interim custody is to ensure that seized property does not remain unused and deteriorate while legal proceedings continue.
Vehicles parked for long periods in police stations or open yards often suffer damage due to weather exposure and lack of maintenance, resulting in unnecessary financial loss. Courts should therefore adopt a practical approach that protects the property’s value while safeguarding the interests of all parties involved.
RC Is Important but Not Final
According to the Supreme Court, the Registration Certificate continues to be a relevant consideration. However, it cannot automatically override credible evidence indicating that another person may be the actual owner or otherwise entitled to interim possession.
The Court stressed that each case must be decided on its own facts after evaluating all available materials rather than applying a rigid rule based solely on vehicle registration records.
Significance of the Judgment
The ruling reinforces the principle that criminal courts should adopt a balanced and fact-based approach while deciding applications for interim custody of seized vehicles.
The judgment is expected to assist courts in resolving disputes involving vehicles that have changed hands but where registration formalities are pending, or where ownership is supported by evidence beyond the Registration Certificate. It also aims to prevent unnecessary deterioration of seized vehicles by facilitating timely and appropriate interim release wherever justified.