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Issues: Whether section 630(1) of the Companies Act, 1956 applies only to present officers and employees of a company or also to past officers and employees who continue to retain company property after termination of employment.
Analysis: The Court followed the later decision construing section 630(1) in a beneficent manner and held that the expression "officer or employee" is not confined to current employees. The provision targets the wrongful withholding or occupation of company property permitted during employment but retained after termination, and the words "any such property" relate back to the company property referred to in the section. A restrictive interpretation excluding former employees was rejected.
Conclusion: Section 630(1) covers past officers and employees as well as present ones, and wrongful retention of company property after cessation of employment is punishable under the provision.