Advocates Appeared:
For the Revisionist : Chandrajeet.
For the Opposite Party : G.A.

Key Points: - The case concerns an application under Section 451 CrPC for release of seized amount during pendency of case under Public Gambling Act, 1867. (!) - Section 451 allows custody and disposal of property produced before the court during an inquiry or trial, and may authorize sale/disposal if property decays or as appropriate after recording evidence. (!) (!) - Section 451 can be invoked only during pendency of an inquiry or trial; investigations do not fall within inquiry or trial, so Section 451 cannot be invoked during investigation. (!) - The Chief Metropolitan Magistrate dismissed the Section 451 application because the case was at the investigation stage; the High Court affirms that investigation is separate from inquiry/trial and cannot support Section 451 at that stage. (!) - Sections 451 to 459 set out disposal of property, with 451 applicable during inquiry/trial and 452 upon conclusion; 457 deals with property seized not produced before a court during inquiry/trial. (!) (!) (!) (!) - The court held that since investigation was pending, no order for custody or disposal of property could be passed under Section 451. (!) (!) - The revision is dismissed, but the revisionist may seek custody/disposal relief at the appropriate stage of trial. (!)

What is the scope of Section 451 of the Code of Criminal Procedure for interim custody and disposal of property during inquiry or trial?

What are the stage-specific applicability and limitations of Sections 451, 452, and 457 in relation to investigation, inquiry, and trial?

What does the judgment hold regarding the admissibility of an application under Section 451 during the pendency of investigation in a case under the Public Gambling Act?