The Delhi High Court in Punita Khatter v. Explorers Travel & Tour Pvt. Ltd. clarified the strict liability imposed by Section 452 of the Companies Act. The petitioner, removed as Managing Director on 11.04.2016, failed to return company property despite repeated demands, arguing she remained a Director and later returned all items. The Court held that her obligation to return property arose immediately upon removal as Managing Director, regardless of her continuing directorship. Section 452 does not require proof of entrustment—once possession becomes unauthorized, failure to return constitutes wrongful withholding. The demand notices were found sufficiently specific, and the Local Commissioner’s report supported the company’s claim that documents remained with her. The Court upheld the trial court’s decision to frame charges, finding a clear prima facie case. The ruling reinforces that officers must promptly return company assets upon cessation of their role and cannot rely on continued association with the company to justify retention.