On 22 April 2020, a three-judge bench held that the weight of the entire mixture — narcotic plus neutral substances — decides whether an NDPS seizure is 'small' or 'commercial', overruling E. Micheal Raj.
On 19 July 2022, a three-judge bench held that 'reasonable grounds' under Section 37(1)(b) NDPS mean credible and plausible grounds, and that custody length or a filed chargesheet do not by themselves relax the bar. The Court cancelled bail.
The Supreme Court set aside a High Court bail order in an NDPS commercial-quantity case, holding the Section 37 twin conditions mandatory and 'reasonable grounds' to mean substantial probable cause, not merely a prima facie view.