Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Criminal LawSupreme Court of India

Income Tax Officer and Anr. v. V. Mohan and Anr.

Civil Appeal · 2021 INSC 886Decided 14 Dec 2021
Civil Appeal Nos. 8592-8593 of 2010
Justice A.M. Khanwilkar · Justice Sanjiv Khanna

Background

A person convicted under the Customs Act had certain properties held in the names of his nephew and niece (the respondents). The Competent Authority under SAFEMA issued forfeiture notices directly to these relatives, treating the properties as the convict's illegally acquired assets screened in their names, without separately serving a "primary" notice on the convict himself (who had in fact died before the notices were issued). The Madras High Court quashed the entire forfeiture action, holding that a primary notice to the convict was mandatory before proceeding against his relatives.

Decision Breakdown

The Supreme Court resolved a conflict between High Courts and held that Section 6 of SAFEMA does not make it mandatory to serve a primary notice on the convict when the property in question is actually held, and in the possession of, the relative in their own name: the notice obligation and burden of proof then falls on that relative directly. It reversed the Madras High Court's view and restored the writ petitions to the High Court's file, so that the respondents' other pending arguments (including inordinate delay in issuing the forfeiture notices) could be decided on their own merits, without disturbing the Court's ruling on the primary-notice question.

Lesson Learnt

Under anti-forfeiture laws like SAFEMA, authorities can proceed directly against a relative who holds a convict's allegedly ill-gotten property in their own name, without first having to serve the convict (or, as here, where the convict is deceased); but other defences such as unreasonable delay remain open to be argued separately.

Income Tax Officer and Anr. v. V. Mohan and Anr. – Legal Case Shots | LegalAware