The Supreme Court upheld the conviction under Sections 49-B and 51 of the Wildlife Protection Act 1972 for illegal possession of tiger skins and animal parts, affirming the statutory presumption of guilt under Section 57. While noting investigation lapses, the Court reduced the sentence from 6 to 3 years’ imprisonment considering the accused’s youth and lack of direct poaching evidence, but imposed a Rs. 25,000 fine to deter wildlife crimes. The judgment balanced strict enforcement of wildlife laws with proportional sentencing.
Facts Of The Case:
The case stemmed from a CBI operation in March 2001 at a Nagpur petrol pump, where appellants Rajesh and Makbool Ahmed were caught with tiger skins, bones, claws, and antler horns in their car. Acting on a tip-off about illegal wildlife trade, the CBI team, with independent witnesses, intercepted their Maruti Esteem car and seized the banned items. The accused claimed procedural flaws, alleging discrepancies in the seizure timing and the absence of buyers/suppliers in the investigation. Charged under Sections 49-B and 51 of the Wildlife Protection Act, 1972, they were convicted by the Chief Judicial Magistrate (2007) and sentenced to 6 years’ rigorous imprisonment, upheld by the Sessions Court (2013) and Bombay High Court (2023). The Supreme Court, while affirming the conviction, noted investigation gaps (e.g., unproven supplier links) but relied on witness testimonies and the statutory presumption of guilt (Section 57). Considering the accused’s youth during the crime and no direct poaching evidence, it reduced their sentence to 3 years’ simple imprisonment with a Rs. 25,000 fine, payable to the Animal Welfare Board to deter wildlife crimes. The judgment emphasized strict enforcement while ensuring proportional punishment.
Procedural History:
The case began with the CBI’s interception and arrest of the accused in March 2001 at a Nagpur petrol pump, where they were caught red-handed with tiger skins and animal parts. Charged under Sections 49-B and 51 of the Wildlife Protection Act, 1972, the Chief Judicial Magistrate, Nagpur (2007) convicted both accused and sentenced them to 6 years’ rigorous imprisonment. The accused appealed to the Sessions Court, Nagpur, which dismissed their appeals in 2013, upholding both conviction and sentence. Their subsequent revision petitions before the Bombay High Court (2023) were also rejected, confirming the lower courts’ decisions. The matter reached the Supreme Court through Special Leave Petitions (SLP Nos. 4650-4651 of 2024). In its 2025 judgment, the Supreme Court upheld the conviction but reduced the sentence to 3 years’ simple imprisonment with a Rs. 25,000 fine, citing the accused’s young age at the time of offense and gaps in the investigation regarding the supply chain. The Court maintained the statutory presumption of guilt under Section 57 of the Act while emphasizing the need for balanced sentencing in wildlife crime cases.
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Court Observation:
The Supreme Court made several critical observations while upholding the conviction but reducing the sentence. The bench emphasized that the presumption of guilt under Section 57 of the Wildlife Protection Act clearly applied, as the appellants were found in possession of banned animal parts. However, the Court noted serious lapses in investigation – particularly the failure to trace the supply chain (the alleged supplier “Madhu”) or identify potential buyers, which left gaps in establishing the complete offense. The judgment highlighted that while wildlife crimes demand strict punishment, sentencing must consider mitigating factors like the accused’s young age at the time (2001) and absence of evidence showing they were directly involved in poaching. Importantly, the Court observed that the recovery was properly documented through independent witnesses (the petrol pump manager and a government official), whose testimonies remained unshaken during cross-examination. The verdict balanced deterrence (maintaining conviction and imposing fine) with proportionality (reducing jail term), sending a message that while wildlife protection laws must be enforced strictly, punishments should fit both the crime and the offender’s circumstances. The Rs. 25,000 fine was specifically directed to the Animal Welfare Board to underscore the conservation purpose behind such prosecutions.
Final Decision & Judgement:
The Supreme Court delivered a balanced final judgment in May 2025, partially allowing the appeals while upholding core legal principles. The bench affirmed the conviction under Sections 49-B and 51 of the Wildlife Protection Act, 1972, ruling that the prosecution had sufficiently proved possession of illegal wildlife articles through credible witness testimony and proper seizure documentation. However, considering the appellants’ young age at the time of offense (2001) and the investigation’s failure to establish their direct involvement in poaching or connect them to the broader supply chain, the Court reduced the sentence from 6 years’ rigorous imprisonment to 3 years’ simple imprisonment. A substantive fine of ₹25,000 was imposed on each appellant, payable to the Animal Welfare Board within 8 weeks, with a 3-month additional imprisonment clause for default. The judgment clarified that while Section 57’s presumption of guilt remained decisive for conviction, sentencing must account for individual circumstances and investigative shortcomings. By directing the fine to wildlife conservation, the Court reinforced the Act’s deterrent purpose while ensuring proportionality. The verdict thus strengthened enforcement of wildlife laws yet demonstrated judicial discretion in sentencing, ordering the appellants – who were on bail – to surrender immediately to serve their modified sentence.
Case Details:
Case Title: Rajesh & Anr. vs. Union of India & Anr. Citation: 2025 INSC 705 Case Number: (@ SLP (Crl.) Nos. 4650-4651 of 2024) Date of Judgment: May 15, 2025 Bench: Justice Ahsanuddin Amanullah & Justice Sudhanshu Dhulia
Download The Judgement Here