In 1945 the Privy Council acquitted Mahbub Shah of murder, holding that Section 34 IPC demands a pre-arranged plan — a shared intention, not a merely similar one — to fasten constructive liability.
In 1947 the Privy Council, through Sir John Beaumont, settled the meaning of 'fact discovered' under Section 27 of the Evidence Act — the bedrock test for every disclosure-and-recovery dispute that follows.