The Supreme Court ruled that interim custody of a vehicle seized in a criminal case cannot be decided solely on the basis of the registration certificate. Courts must examine the overall circumstances of each case, including the nature of the offence, the claimant's connection to the vehicle, and the purpose of seizure. The registration certificate is merely one evidentiary factor, not a determinative document. The ruling clarifies the judicial approach to Section 451 and 457 CrPC applications for interim custody.

When a vehicle is seized during a criminal investigation, the accused or any claimant may approach the court for its interim custody pending trial. Traditionally, many trial courts treated the registration certificate as near-conclusive proof of ownership and therefore the primary basis for granting or refusing custody. The Supreme Court's ruling disrupts this mechanical approach. The Court emphasised that criminal proceedings involve complex factual matrices — the vehicle may be seized as an instrument of crime, a stolen property, or merely incidental to an arrest — and each scenario demands a different judicial analysis. A registration certificate proves only that a person was registered as owner at a given point; it says nothing about who was in actual possession, whether the vehicle was used in the offence, whether releasing it would destroy evidence, or whether a third party has a superior claim. Practically, this matters because courts now have an affirmative duty to reason through the circumstances before granting interim custody under Section 451 CrPC or Section 457 CrPC (now mirrored under BNSS). For CLAT PG aspirants, this judgment is important as a passage-based question source: it tests the ability to apply a stated legal principle — that registration is one factor among many — to varied hypothetical scenarios involving claimants with or without registration certificates.