Supreme Court of India

Nathulal v State of Madhya Pradesh

AIR 1966 SC 4319661 min read
The case in brief30-second read
Facts
The appellant, a grain dealer, stored foodgrains without a licence after applying for one and believing it would be granted. He was prosecuted under S.7 of the Essential Commodities Act 1955.
Issue
Whether mens rea is an ingredient of the offence.
Held
Mens rea is an essential ingredient unless the statute excludes it expressly or by necessary implication. The appellant acted in a bona fide belief, so he had no guilty mind. The conviction was set aside.
Principle
The presumption of mens rea applies to statutory offences, even in welfare statutes, unless clearly excluded.
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Facts

  • The appellant, a grain dealer, stored foodgrains without a licence after applying for one and believing it would be granted. He was prosecuted under S.7 of the Essential Commodities Act 1955.

Issue

  1. Whether mens rea is an ingredient of the offence.

Held

  • Mens rea is an essential ingredient unless the statute excludes it expressly or by necessary implication. The appellant acted in a bona fide belief, so he had no guilty mind. The conviction was set aside.

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Citation

Nathulal v State of Madhya Pradesh AIR 1966 SC 43

Reported: https://indiankanoon.org/doc/1834977/. This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.