This compilation indexes twelve Indian court orders and judgments — spanning the Supreme Court, High Courts of Jharkhand, Bombay, Kerala, Gauhati, Telangana, and Karnataka — in which Section 47 appears among the sections cited, delivered between August 2025 and April 2026. The cases arise across a wide range of proceedings including civil execution disputes, customs bail applications, GST input tax credit matters, property transfer controversies, and writ petitions concerning release of imported goods. This index is intended for use by legal researchers, in-house counsel, and tax professionals tracking how Section 47 surfaces across different statutes and procedural contexts in Indian courts.

Research notice: This page is a structured case-law index for research and reference purposes only. It is not legal or tax advice. Readers must verify each ruling against the full text of the judgment and check for any subsequent stays, appeals, or reversals before relying on it.

The statutory framework in one paragraph

"Section 47" is not a monolithic provision — the section number appears across multiple Indian statutes, including the Code of Civil Procedure, 1908 (questions relating to execution of decrees), the Customs Act, 1962 (clearance of imported goods), the Transfer of Property Act, 1882, the CGST Act, 2017, and various state tenancy enactments, among others. The rulings indexed below demonstrate this multiplicity: courts in the same period have applied "Section 47" in contexts as varied as execution proceedings against foreign judgments, customs clearance of imported goods, bail applications under the NDPS Act read with customs provisions, GST input tax credit claims, and land tenancy disputes. Researchers should confirm which statute's Section 47 is engaged in each ruling before drawing cross-case inferences.

The 12 rulings

1. Messer Griesheim Gmbh (Now Called Air vs Goyal Mg Gases Private Limited

Bench: Supreme Court of India
Date: 21 April 2026
Sections engaged: 13, 47
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Supreme Court as Civil Appeal No. of 2026, arising out of SLP (C) No. 4774 of 2023. Per the source preview, the judgment (2026 INSC 401, reportable) addresses the statutory scheme governing enforcement of foreign judgments, with one of the issues framed as whether the judgment of the English Court satisfies the applicable conditions. The preview indicates a structured judgment with chapters covering the impugned order, submissions by both sides, and the statutory scheme — the full reasoning is not reproduced in the source preview available.

2. Pinki Devi @ Asha Devi vs Arbind Kumar Gupta

Bench: Jharkhand High Court
Date: 24 March 2026
Sections engaged: 13, 47
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was listed before the Jharkhand High Court as Civil Revision No. 17 of 2025, along with CMP No. 592 of 2025. Per the source preview, CMP No. 592 of 2025 was filed for quashing of an order dated 18.02.2003 passed by the Permanent Lok Adalat, Ranchi, in P.L.A. No. 270 of 2001. The two petitions were assigned to this bench and listed accordingly; the full merits and outcome are not reproduced in the source preview available.

3. Santa Monica Farm Produce Private vs Union Of India

Bench: Bombay High Court
Date: 5 February 2026
Sections engaged: 47, 124
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a writ petition filed under Article 226 of the Constitution of India before the Bombay High Court (Writ Petition (L.) No. 42323 of 2025) seeking a direction to release imported goods — specifically approximately 8,000 net kilograms of USA-origin in-shell walnuts purchased from Diamond Foods LLC, USA — which had been held up following Bills of Entry lodged on 08 December 2025. Per the source preview, the petitioner sought forthwith release of the goods for commercial sale in India; the full outcome is not reproduced in the source preview available.

4. Manoj Kumar Singh vs Principal Commissioner

Bench: Jharkhand High Court
Date: 21 January 2026
Sections engaged: 100, 16(2), 16(4), 16(5), 300, 39, 47
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. (T) No. 7467 of 2025) was filed before the Jharkhand High Court against the Principal Commissioner, Central Goods and Service Tax & Central Excise, Ranchi. Per the source preview, the court noted that the question of unconstitutionality of a sub-section of the CGST Act need not be gone into at that stage, as the relevant provision had been amended by inserting a new sub-section; the court also noted a CBIC circular issued in that regard. The full operative order and outcome are not reproduced in the source preview available.

5. Danesh Singh vs Har Pyari (Dead) Thr. Lrs

Bench: Supreme Court of India
Date: 15 December 2025
Sections engaged: 52, 47
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Supreme Court as Civil Appeal No. 14761 of 2025, arising out of SLP(C) No. 14461 of 2019 (2025 INSC 1434, reportable). Per the source preview, the judgment addresses the Transfer of Property Act, 1882, specifically framing the issue of whether the transfer of the suit property is hit by the doctrine of lis pendens. The preview indicates a structured judgment covering trial court findings, party submissions, and analysis, with multiple respondents categorised by their role in the execution proceedings; the full holding is not reproduced in the source preview available.

6. Mashooda M.T.P vs The Commissioner

Bench: Kerala High Court
Date: 4 December 2025
Sections engaged: 47, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a bail application (B.A. No. 12138 of 2025) filed before the Kerala High Court under Section 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, in connection with Crime No. OS 178/2025 of Air Customs, Calicut International Airport, Kozhikode. Per the source preview, the petitioner/accused was before the court in connection with a matter arising from the Special Court (Atrocities against SC/ST), Manjeri; the bail application came up for admission on 04.12.2025 and was disposed of the same day. The full reasoning and outcome are not reproduced in the source preview available.

7. Sri Bipul Kumar Das Alias Bipul Das vs Union Of India

Bench: Gauhati High Court
Date: 25 November 2025
Sections engaged: 37, 47, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a bail application (Bail Appln./3200/2025) filed before the Gauhati High Court under Section 483 of the BNSS 2023, by a petitioner who had been detained since 05.09.2024 in connection with NDPS Case No. 59/2025 arising out of Customs Case No. 01/CL/NARC/AS/GAU/2024-25. Per the source preview, the gist of accusation was that on 04.09.2024, officers of the Anti-Smuggling Unit, Guwahati Customs Division, received information that the petitioner had stocked narcotic substances, believed to be ganja, at his residence. The full order on the bail application is not reproduced in the source preview available.

8. Shri Mukesh Agarwal vs The Union Of India And 2 Ors

Bench: Gauhati High Court
Date: 24 October 2025
Sections engaged: 132(1)(a), 132(1)(i), 132(5), 35(3), 41A, 47, 48, 69, 70
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a bail application (Bail Appln./3440/2025) filed before the Gauhati High Court, with the respondents represented by the Senior Intelligence Officer, Directorate General of Goods and Service Tax Intelligence, Guwahati Zonal Unit. Per the source preview, the matter was heard by the court with senior counsel appearing for the petitioner; the full factual background, the specific grounds urged, and the operative outcome are not reproduced in the source preview available.

9. Dr.K.Manmohan Reddy vs The State Of A.P. Rep. By Prl. Secretary

Bench: Telangana High Court
Date: 6 October 2025
Sections engaged: 16, 37, 38, 47, 91
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a batch matter before the Telangana High Court comprising numerous Civil Revision Petitions (including CRP No. 5279/2016 and connected matters) and Writ Petitions. Per the source preview, the proceedings involved, among other documentary evidence, pahani extracts for survey numbers across multiple years and a registered sale deed dated 2-9-1961; the source preview also references a permission document under a tenancy enactment. A common order was passed across the batch; the full findings and outcome are not reproduced in the source preview available.

10. Page No.# 1/39 vs Shri Shashi Kumar Choudhary And Anr

Bench: Gauhati High Court
Date: 24 September 2025
Sections engaged: 132, 47, 48
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was filed as Crl. Rev. P./224/2025 before the Gauhati High Court, with Union of India represented by the Directorate General of Goods and Services Tax Intelligence, Guwahati Zonal Unit, as the petitioner, and Shri Shashi Kumar Choudhary (Proprietor, M/s S K Enterprise, GSTIN 18ACNPC6284D1ZJ) and Shri Ankit Choudhary (Proprietor, M/s Ankit Enterprises, GSTIN 18CIEPC6605B1ZS) as respondents. Per the source preview, the application was filed under Section 438 read with other provisions; the hearing date was 05.09.2025 and the judgment and order (CAV) was pronounced on 24.09.2025. The full operative findings are not reproduced in the source preview available.

11. Karnataka State Medical Supplies vs Plasti Surge Industries Pvt Ltd

Bench: Karnataka High Court
Date: 1 September 2025
Sections engaged: 47
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a writ petition (Writ Petition No. 29449 of 2024 (GM – CPC)) filed before the Karnataka High Court under Articles 226 and 227 of the Constitution of India, reserved for orders on 21.08.2025 and pronounced on 01.09.2025. Per the source preview, the petition sought to call for records in Comm. Execution Petition No. 517/2023 pending before the LXXXVII Additional City Civil Court, Commercial Court Complex (CCH-88), Bangalore, and to quash that execution petition. The full reasoning and outcome are not reproduced in the source preview available.

12. Page No.# 1/6 vs The Union Of India

Bench: Gauhati High Court
Date: 26 August 2025
Sections engaged: 2(iii), 37, 47
Outcome: Outcome not specified in source
Procedural / substantive ground: This was a bail application (Bail Appln./2058/2025, citation 2025:GAU-AS:11546) filed before the Gauhati High Court under Section 483 of the BNSS, 2023, by the petitioner Bipul Kumar Das alias Bipul Das, who had been detained since 05.09.2024 (for more than 11 months per the source preview) in connection with Customs Case No. 01/CL/NARC/AS/GAU/2024-25, dated 04.09.2024. Per the source preview, the accusation was that on 04.09.2024, officers of the Anti-Smuggling Unit, Guwahati Customs Division, received information that the petitioner had stocked narcotic substances, believed to be ganja, at his residence. The full outcome of this bail application is not reproduced in the source preview available.

Patterns across these 12 rulings

Readers should note that the source previews for all twelve cases in this compilation do not include a fully reproduced operative holding or outcome reasoning. Observations below are therefore limited to structural and contextual patterns visible from the preview text and case identity fields.

Section 47 as a multi-statute citation marker. Across all twelve cases, "Section 47" is cited alongside sections drawn from entirely different statutes — the Code of Civil Procedure, the Customs Act, the CGST Act, the Transfer of Property Act, the NDPS Act, and state tenancy legislation. This confirms that the section number alone is not a reliable basis for clustering cases thematically; the parent statute must always be identified first.
Bail applications form a significant cluster. At least four of the twelve rulings (cases 6, 7, 8, and 12) are bail applications filed under the BNSS or its predecessor, arising in the context of customs or GST enforcement proceedings. Section 47 appears in these matters alongside sections concerning arrest, detention, and bail in the context of smuggling or tax evasion allegations.
Execution and enforcement proceedings recur. Cases 1, 5, 10, and 11 arise in the context of execution or enforcement of decrees or foreign judgments, with Section 47 of the Code of Civil Procedure or related provisions on the determination of questions in execution proceedings being the contextually relevant provision. This cluster reflects ongoing litigation around enforcement rights in commercial and civil disputes.
Customs clearance and import disputes appear. Case 3 (Santa Monica Farm Produce) involves a writ petition seeking release of imported goods held at customs, with Section 47 of the Customs Act (relating to clearance of goods for home consumption) being the contextually relevant provision.
Outcome data is uniformly unavailable in the source previews. In all twelve cases, the outcome direction is recorded as "Outcome not specified in source," and no operative holding is reproduced in the available text previews. Researchers should treat this compilation as a discovery index and retrieve the full judgment text from the original court portals or indiankanoon.org before drawing any conclusions about legal outcomes.

How to use this compilation

This compilation is designed as a starting point for case discovery, not as a substitute for reading the full judgments. Each entry identifies the court, bench, date, and sections engaged — information sufficient to locate the original order on indiankanoon.org, the official court portals (e.g., the Supreme Court's NJDG, the respective High Court websites), or subscription legal databases. Researchers should retrieve the full text of each judgment to understand the operative holding, the specific statute under which Section 47 was invoked, and whether the matter was finally disposed of or is still pending before a higher forum.

Because "Section 47" spans multiple statutes, it is particularly important to verify the regulatory regime of each ruling before drawing any inference about income-tax, customs, GST, or civil procedure law. A bail application under the Customs Act engages an entirely different body of law from a writ petition challenging a GST assessment order, even if both cite "Section 47" in the sections list. Cross-regime comparison without verifying the parent statute is a common research error this index is designed to help researchers avoid.

Finally, researchers should check for subsequent developments in each matter: whether a stay was granted by a higher court, whether an SLP was filed following a High Court order, or whether the matter has been remanded or settled. Tax and commercial litigation in India frequently involves multiple rounds of proceedings, and the ruling indexed here may represent only one stage in a longer procedural history. Parallel CBDT or CBIC instructions, circulars, and notifications may also be relevant to the substantive questions engaged in several of these matters.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 47 in Indian Courts: 12 Procedural Rulings Across Regimes (2025–2026)