In Joshi Purshottam Jethanand v State of Kutch (1954), the police officer withheld a villager’s travel…

In Joshi Purshottam Jethanand the Supreme Court held that fear of injury could arise from the implied threat of prosecution or from the wrongful withholding of the villager's genuine travel document; finding no reason to interfere, "It upheld the conviction for extortion and dismissed the appeal". The outcomes "It acquitted the officer because withholding a travel document could not involve fear of injury", "It held that only a civil debt was established" and "It left the extortion conviction undecided and remanded that issue" do not describe the decision.