In Narayan Das v. State of Chhattisgarh, decided on July 17, 2025, the Supreme Court clarified the scope of Section 32-B of the NDPS Act. The petitioner was convicted under Section 21(c) for possession of 236 vials of Codeine-based cough syrup and sentenced to 12 years of rigorous imprisonment and a fine. The High Court reduced the sentence to the statutory minimum of 10 years, wrongly holding that only the factors listed under Section 32-B clauses (a) to (f) can justify a sentence above the minimum. The Supreme Court corrected this view, ruling that Section 32-B preserves judicial discretion, and the listed factors are illustrative, not exhaustive. Courts may consider any relevant factor, including the nature and quantity of the substance or the accused’s background. While the Court upheld the reduced sentence without intervening, it clarified that trial courts are not limited to the enumerated factors under Section 32-B when imposing a sentence above the statutory minimum.