The Allahabad High Court has directed the Uttar Pradesh government to pay significant financial compensation to a vehicle owner after declaring the confiscation of his commercial truck arbitrary and legally unsustainable. Justice Sandeep Jain, presiding over the case, quashed the confiscation orders passed by the District Magistrate of Mirzapur and the appellate authority, ruling that the state had failed to establish any credible evidence to support allegations of cattle smuggling. The court ordered the immediate release of the DCM Eicher vehicle, which had been impounded by the police in September 2023.

In addition to restoring the vehicle, the court mandated that the state pay the petitioner, Tej Prakash, compensation at a rate of ₹40,000 per month, calculated from the date of the vehicle's seizure in September 2023 until the date of its actual release. A further sum of ₹25,000 was awarded to cover the mental agony, financial hardship, and avoidable litigation costs imposed upon the petitioner. The court emphasized that if the state fails to make these payments within one month, the amount will accrue simple interest at a rate of 8% per annum. Furthermore, the bench noted that the state government is at liberty to conduct a departmental inquiry to fix responsibility on the officers who executed the illegal confiscation and recover the compensation from those individuals.

Absence of Evidence in Administrative Actions

The dispute originated when local police in Mirzapur intercepted the petitioner's vehicle while it was transporting two bullocks. Authorities subsequently initiated confiscation proceedings under the Uttar Pradesh Prevention of Cow Slaughter Act, 1955, alleging that the animals were being transported to West Bengal for slaughter. Throughout the proceedings, the district authorities maintained that the proximity of Mirzapur to the neighbouring state of Bihar served as sufficient grounds to assume an intent to move the animals across state lines for illegal slaughter.

Justice Jain sharply criticized this line of reasoning, finding that the administrative action was based entirely on conjecture rather than objective evidence. "Such a conclusion is founded merely upon conjectures and surmises and is wholly unsupported by any independent evidence," the court observed. The bench clarified that the mere existence of an interstate or international boundary cannot, by itself, serve as proof of illegal transportation. In the absence of positive and cogent evidence demonstrating that the destination of the vehicle was outside Uttar Pradesh or that the transit was specifically intended for slaughter, the state could not legally invoke statutory presumptions against the owner.

Legal Interpretations of Transport Provisions

Central to the court’s decision was a clarification of the regulatory framework surrounding the transportation of livestock within Uttar Pradesh. The court reiterated that the legal requirement for a transport permit applies strictly when cow progeny is being moved to a location outside the territorial boundaries of the state. Because the authorities failed to produce any records proving an interstate destination, they could not justify the seizure based on a lack of permits.

Moreover, the court noted that the state’s allegations regarding animal cruelty were entirely unsubstantiated. Although the police claimed the animals were transported in a cruel manner, no veterinary examination report was presented to support this assertion. "In such circumstances, it cannot be presumed, merely on the basis of the manner of transportation alleged by the authorities, that the animals were being transported in a cruel manner in the petitioner's vehicle," the judgment stated. Without evidence of injuries, mutilation, or life-endangering conditions, the provisions of Section 5-B of the Act could not be applied. The court observed that the foundational facts required for such serious allegations were absent, rendering the confiscation proceedings a manifestation of non-application of mind .

Protecting Fundamental Rights to Livelihood

The court took extensive note of the financial distress suffered by the petitioner. It was highlighted that the vehicle, which was acquired through a loan from what is now Poonawalla Fincorp Limited, served as the petitioner’s primary source of livelihood. The prolonged and illegal detention of the asset prevented the petitioner from working, which in turn hindered his ability to meet monthly loan obligations, resulting in the accrual of penal interest.

The court underscored that Article 21 of the Constitution protects both life and the right to livelihood. By acting in an arbitrary and illegal manner, the state’s instrumentalities infringed upon the petitioner’s fundamental rights. Relying on established Supreme Court precedents, the High Court held that the state must provide monetary amends when its officers breach their public duty. The award of compensation in this matter is designed to serve as both a remedy for the victim and a deterrent against the arbitrary exercise of statutory powers by administrative officials. The final order requires the local authorities to process the vehicle's release immediately, marking an end to a protracted legal battle that arose from a seizure the court deemed completely devoid of legal merit.