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Conviction under section 120-B of the Indian Penal Code based on a charge against multiple individuals, acquittal of co-conspirators, and legality of the conviction. Analysis: The case involved the appellant and three other accused charged with criminal conspiracy in relation to fraudulent activities involving import licenses. The trial court acquitted all accused, but the High Court reversed the decision, convicting the appellant under section 120-B of the Indian Penal Code while acquitting the other three accused. The High Court found the appellant guilty based on the alleged conspiracy and fraudulent documents presented. The appellant sought special leave to appeal on the legality of his conviction. The key legal issue revolved around whether the appellant, as the only remaining convicted individual, could be found guilty of criminal conspiracy under section 120-B of the Indian Penal Code when his co-accused were acquitted. The definition of criminal conspiracy in section 120-A requires the involvement of two or more persons, making it impossible for a single individual to be convicted of conspiracy. Legal authorities and precedents, including Archbold's Criminal Pleading and the case of The King v. Plummer, supported this principle. The judgment emphasized that the essence of conspiracy lies in the agreement between multiple parties, and the acquittal of co-accused undermines the basis for convicting a sole individual of conspiracy. The court cited Indian cases like Gulab Singh v. The Emperor and King-Emperor v. Osman Sardar, which upheld the requirement of multiple parties for a conspiracy charge. Ratanlal's Law of Crimes further clarified that if co-accused are acquitted, the remaining individual cannot be convicted of conspiracy. Therefore, the appellant's conviction under section 120-B was deemed illegal due to the acquittal of his alleged co-conspirators. Consequently, the Supreme Court allowed the appeal, quashing the appellant's conviction under section 120-B of the Indian Penal Code and the associated sentence. However, the convictions under other sections and the corresponding sentences were upheld as they were not affected by the issue of conspiracy. The judgment reaffirmed the fundamental legal principle that a single individual cannot be convicted of criminal conspiracy when the co-conspirators are acquitted.
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