Special confiscation scheme bars Section 482 relief for seized forest vehicles once proceedings begin.

The West Bengal Forest Act created a self-contained confiscation scheme for seized forest produce and vehicles, with notice, hearing, appeal, finality and an express bar on jurisdiction. Once confiscation proceedings were initiated, the bar in Section 59-G excluded criminal courts and other fora from dealing with custody, possession, delivery, disposal or distribution of the seized property. The High Court therefore could not use its inherent power under Section 482 of the Code of Criminal Procedure to order interim release, because that power applies only to proceedings before a criminal court and cannot override the special statutory bar. Relief had to be sought within the confiscation scheme, subject to judicial review where available.

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Issues: Whether the High Court could invoke its inherent power under Section 482 of the Code of Criminal Procedure, 1973 to order interim release of vehicles or forest produce once confiscation proceedings under the Indian Forest Act, 1927 as amended by the State of West Bengal had been initiated, and whether such confiscation proceedings were independent of criminal proceedings.

Analysis: The statutory scheme showed that seizure of forest produce or vehicles could lead to prosecution, confiscation, or both, and that the West Bengal amendments created a self-contained machinery for confiscation, notice, hearing, appeal, finality, and an express bar of jurisdiction. The confiscatory power vested in the authorised officer was independent of prosecution and was designed to protect forest wealth and prevent ecological depletion, warranting a purposive construction consistent with the constitutional duty to preserve forests. Once a confiscation proceeding was initiated, Section 59-G barred the jurisdiction of criminal courts and other fora in respect of custody, possession, delivery, disposal, or distribution of the seized property, so the High Court could not use Section 482 to grant interim release. The High Court's inherent power under that provision is available only in relation to proceedings before a criminal court and cannot override a special statutory bar attaching to confiscation proceedings.

Conclusion: The High Court had no jurisdiction under Section 482 of the Code of Criminal Procedure, 1973 to release the seized vehicles after initiation of confiscation proceedings under the Act; such matters could be pursued only in accordance with the special statutory scheme and by judicial review where available.

Final Conclusion: The special confiscation mechanism under the Forest Act prevails over the general criminal-court power of interim custody, and the High Court's interference by way of Section 482 was unsustainable.

Ratio Decidendi: Where a special statute creates an independent confiscation process and expressly bars jurisdiction over seized property after initiation of that process, the High Court cannot invoke inherent criminal jurisdiction to interim release of the property.

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