Confiscation of LPG cylinders was upheld after the claimant failed to prove ownership.

On 8 September 2011, a Food Inspector inspecting the applicant’s mobile shop found eight domestic LPG cylinders in an adjoining room—two filled and six empty.

The applicant reportedly stated that four cylinders belonged to him and four to consumers, and that he charged consumers ₹10–20 above the prescribed price.

He produced no licence or other authority for the cylinders, which were seized.

The Collector ordered their confiscation under Section 6-A of the Essential Commodities Act, 1955.

That order was set aside and remanded for fresh adjudication; on remand, the Collector again ordered confiscation.

The Sessions Court dismissed the applicant’s appeal under Section 6-C, leading to this revision.

Whether the Sessions Court’s decision upholding confiscation of the eight LPG cylinders suffered from any illegality or infirmity warranting interference in revision

Whether the applicant established a basis to prevent confiscation by showing ownership of any of the cylinders

Section 6-A of the Essential Commodities Act, 1955, provides for confiscation of essential commodities in the circumstances specified by that provision; Section 6-C provides for an appeal against an order of confiscation.

The Court considered the LPG (Regulation of Supply and Distribution) Order, 2000, which was the basis of the alleged violation.

It applied its revisional jurisdiction to determine whether the Sessions Court’s order disclosed an illegality or infirmity warranting interference.

The Court found that eight LPG cylinders were stored in a room adjoining the applicant’s shop and that the applicant had produced no documents before the Collector supporting his claim to ownership of any of them.

It therefore rejected the ownership-based challenge and found no illegality or infirmity in the Sessions Court’s decision upholding confiscation.

The Court did not identify a separate evidentiary or statutory test beyond its review of the record and the impugned order.

The criminal revision was dismissed.