#CrPC Section 451

Interim release of a vehicle seized under the Gujarat Prohibition Act can be ordered under CrPC Section 451 upon furnishing satisfactory security, despite Section 98(2). This permits owners to recover seized conveyances pending trial, expanding procedural relief in prohibition cases.

Supreme Court clarifies that interim custody of seized property under CrPC Sections 451 and 457 hinges on prima facie possession, not registration. Vehicles registered in a director’s name were granted to the company in actual possession, setting a precedent for disputes over seized assets.

Madhya Pradesh High Court holds that seized vehicles under NDPS Act cannot be kept at police stations indefinitely; must be released on bond with conditions to prevent depreciation.