The Supreme Court ruled that substantial compliance with Section 42 of the NDPS Act suffices when narcotics information is received in circumstances demanding immediate interception of a moving vehicle. Full compliance with the written-information-recording requirement under S.42 is impractical in such emergencies. The Court distinguished between situations allowing prior deliberation and those demanding instant action, holding that officers need not strictly satisfy every procedural formality under S.42 when exigent circumstances exist. This reinforces the earlier principle from Karnail Singh v. State of Haryana.

Section 42 NDPS Act imposes a crucial procedural safeguard: when a police officer has 'reason to believe' that a narcotics offence has been committed, he must record that information in writing before conducting a search, and send a copy to his immediate superior. The purpose is to prevent fabrication of evidence post-seizure.

However, the Supreme Court has long recognized two categories of situations. First, where there is prior information and adequate time — here, strict compliance with S.42 is mandatory and failure vitiates the search. Second, where information is received in circumstances requiring immediate action (such as intercepting a moving vehicle) — here, substantial compliance suffices.

The distinction matters enormously for trials. If a court finds non-compliance with S.42 in the first category, it may render the entire seizure and subsequent evidence inadmissible. But in moving-vehicle scenarios, the Court applies a 'substantial compliance' standard: if the officer recorded information at the earliest practicable moment after interception and informed his superior promptly, that is sufficient.

This ruling reaffirms Karnail Singh v. State of Haryana (2009), where the Supreme Court first systematically explained when strict versus substantial compliance applies. CLAT PG examiners frequently present fact patterns where the officer either delayed writing or never wrote information down, asking aspirants to evaluate whether the seizure is valid — directly testing this distinction.