Registered owner governs confiscation under narcotics law; hire-purchase financier is not treated as the owner.

For confiscation of a conveyance used to carry narcotic drugs or psychotropic substances, the term "owner" was construed to mean the registered owner under the Motor Vehicles Act, not a hire-purchase financier retaining title. The provision was read in light of its confiscatory and deterrent purpose, and a financing arrangement could not defeat liability merely because legal title remained with the financier. On that construction, the financier was not entitled to claim the protections available to an owner, and confiscation of the vehicle was sustainable.

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Issues: Whether, for the purposes of confiscation under Section 60(3) of the Narcotic Drugs and Psychotropic Substances Act, 1985, the expression "owner" includes a hire-purchase financier retaining title, or is confined to the registered owner of the conveyance.

Analysis: Section 60(3) makes an animal or conveyance used in carrying narcotic drugs or psychotropic substances liable to confiscation unless the owner proves lack of knowledge or connivance and due precaution. The Act does not define "owner". Accepting the hire-purchase financier's construction would defeat the confiscatory and deterrent purpose of the provision by protecting vehicles used for narcotics merely because title is retained under a financing arrangement. In that statutory setting, the expression was construed to mean the person in whose name the vehicle stands registered under the Motor Vehicles Act.

Conclusion: The hire-purchase financier was not to be treated as the owner for Section 60(3), and the confiscation order was sustainable.

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