Accretion to seized funds supports payment of interest where retained money was later found unrelated to contravention.

Interest earned on seized funds later found unrelated to the alleged contravention was held payable to the petitioners as accretion to the original money. The Court applied the doctrine of accretion and treated the fixed-deposit interest as part of the seized amount, noting that the petitioners had been deprived of the use of their money while it was retained by the department. It further relied on the principle that, in an appropriate Article 226 matter, interest may be awarded to restore the aggrieved party to the position it would have occupied had the money not been wrongfully retained. The petitioners were therefore entitled to the accrued interest and further interest on the withheld interest.

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Issues: Whether interest earned on seized money, later found not to be involved in the alleged contravention and returned to the petitioners, was payable to them as accretion to the seized amount.

Analysis: The seized cash and cheque were placed in fixed deposits by the department and earned interest during the period of retention. The order of adjudication exonerated the petitioners and established that the seized amounts were not involved in any contravention. The Court applied the doctrine of accretion and held that interest earned on the invested seized funds formed part of the original money. It also noted that the petitioners had been deprived of the use of their money for a substantial period and that withholding the earned interest would be unjustified. The Court further relied on the principle that, in a proper case under article 226, interest may be awarded to place the aggrieved party in the position it would have occupied had the money not been wrongfully retained.

Conclusion: The petitioners were entitled to the interest earned on the seized amounts, together with further interest on the withheld accrued interest at the rate directed by the Court.

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