Facts: The petitioner was convicted by a Judicial Magistrate under Section 7(i) and (iii) of the Prevention of Food Adulteration Act, 1954, and sentenced to six months’ rigorous imprisonment along with a fine of ₹1,000. This conviction and sentence were affirmed by the Additional Sessions Judge. The petitioner challenged the appellate decision in the Madhya Pradesh High Court, but it was dismissed without merit consideration. Subsequently, the petitioner approached the Supreme Court.

Issue: Can the High Court exempt a convict from surrendering under Section 482 of the CrPC?

Observation: The Supreme Court stated that it is impermissible for the High Court to exercise its inherent powers under Section 482 of the CrPC to exempt a convict from the requirement of surrendering, especially given the concurrent findings of conviction. The High Court determined that the petitioner’s application seeking exemption from surrender was not maintainable, citing Rule 48