The court upheld the legality of search and seizure under Section 132 of the Income Tax Act, asserting that the 'reason to believe' standard is justiciable, but not the adequacy of those grounds.

1. It will not be an unfaithful summary of the history to say that for ages searches and seizure of documents and objects alleged to be incriminating have been responsible for many a battle at the bar. The safeguards of liberty of the subjects in this behalf have been forged out of conflicts between overzealous prosecutors on the one hand and not very nice people on the other. In preserving this liberty of the subjects the Courts always bear in mind that under our Constitution the concept of liberty is wider and the prisoner's dream of freedom from custody alone is not liberty. The present writ petition is directed against searches conducted on 10th August, 1966 at the residence of the petitioners at 35 Rajpur Road, Delhi, and other places occupied by the petitioners in connection with their business by a group of officers headed by Shri Rajendra Mohan, Income - tax Officer, respondent No. 2. The search was held in pursuance of the various authorizations issued by the Director of Inspection (Investigation) under S.132 of the Income - tax Act, 1961 , and R.112 (1) of the Income - tax Rules, 1962. It is sufficient to reproduce one of the authorisation forms signed by the Director of Inspection (Investigation) as all other forms are exactly in the same language: "
(See R.112) 
Warrant of Authorisation under S.132 of the and R.112 (1) of the Income - tax Rules, 1962.
The Income - tax Officers, S / Shri R. P. Gautam, P. K. Sharan, Rajendra Mohan, Govind Ram, S. N. Tandon, P. L. Madan, P. Ranganathan, R. R. Gupta, Miss S. Ghosh and Miss M. Sehgal, I. T. Os. Delhi.
Whereas information has been laid before me and on the consideration thereof, I have reason to believe that : -
If a summons under sub-section (1) of S.37 of the Indian Income - tax Act, 1922 or under sub-section (1) of S. 131 of the or a notice under sub-section (4) of S.22 of the Indian Income - tax Act, 1922 or under sub-section (1) of S.142 of the is issued to S. Balwant Singh to produce, or cause to be produced, books of account or other documents which will be useful for, or relevant to proceedings, under the Indian Income - tax Act, 1922 or under the , he would not produce, or cause to be produced such books of account or other documents as required by such summons or notice;
S. Balwant Singh is in possession of any money, bullion, jewellery or other valuable article or thing and such money, bullion, jewellery or other valuable article or thing represents either wholly or partly income or property which has not been disclosed for the purposes of the Indian Income - tax Act, 1922 or the :
And whereas I have reason to suspect that such books of account, other documents, money, bullion, jewellery or other valuable article or thing have been kept and are to be found at the premises of S. Balwant Singh at Bawa House, 35, Rajpur Road, Delhi including outhouses, garages and other appurtenances thereto;
This is to authorise and require you as overleaf (name of the Inspecting Assistant Commissioner of Income - tax or the Income - tax Officer).
a. to enter and search the said premises;
b. to place identification marks on such books of account and documents as may be found in the course of the search and as you may consider relevant to or useful for the proceedings aforesaid and to make a list thereof together with particulars of the identification marks;
c. to examine such books of account and documents and make or cause to be made, copies or extracts from such books of account and documents;
d. to seize any such b