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White Black Legal – International Law Journal · ISSN 2581-8503
DRUG ABUSE AMONG YOUTH: IS THE NDPS ACT SUFFICIENT OR SHOULD INDIA SHIFT TOWARDS A PUBLIC HEALTH MODEL?
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Abstract
DRUG ABUSE AMONG YOUTH:
IS THE NDPS ACT SUFFICIENT OR SHOULD INDIA SHIFT TOWARDS A PUBLIC HEALTH MODEL?
AUTHORED BY - PRAKHAR
JAISWAL
Research Scholar, HPNLU,
Shimla
Abstract
Drug abuse among youth has emerged as a significant social,
legal and public-health concern in India, raising fundamental questions
regarding the effectiveness and appropriateness of a predominantly criminal-law
response. The Narcotic Drugs and Psychotropic Substances Act, 1985
(NDPS Act) establishes a stringent statutory framework governing the
possession, production, trafficking and consumption of narcotic drugs and
psychotropic substances, with severe penalties intended to deter illicit drug
activity. However, the increasing prevalence of substance dependence among
young people raises questions about whether criminalisation alone can
adequately address the underlying causes and consequences of drug abuse. This
paper critically examines whether the existing NDPS framework is sufficient to
respond to youth drug abuse or whether India should move towards a public-health-oriented
model that integrates prevention, treatment, rehabilitation and
harm reduction with appropriate criminal enforcement. The study adopts a doctrinal and analytical
legal methodology,
examining the NDPS Act, relevant judicial decisions, constitutional principles,
government policies and international approaches to drug control. Particular
attention is given to the distinction between drug users and organised
traffickers, the right to life and personal liberty under Article 21,
rehabilitation mechanisms, treatment accessibility and the proportionality of
criminal sanctions. The paper argues that while stringent enforcement remains
necessary against trafficking and organised drug networks, excessive reliance
on punishment may inadequately address dependency among young users. A balanced
approach combining criminal justice with evidence-based prevention, voluntary
treatment, rehabilitation, counselling and social reintegration would better
protect youth and advance public health. The study ultimately advocates a rights-based,
proportionate and public-health-centred drug policy for India.
Keywords: Drug Abuse; Youth; NDPS
Act, 1985; Public Health Model; Rehabilitation.
Introduction
Drug
abuse among young people has emerged as a serious social, legal and
public-health challenge in India. Adolescence and early adulthood constitute
particularly vulnerable stages because experimentation, peer influence,
psychological pressures, unemployment, family difficulties and easy
availability of substances can contribute to problematic drug use.
Internationally, the United Nations Office on Drugs and Crime treats drug use
among adolescents and young people as an important component of drug-demand analysis,
including monitoring illicit drug use among students aged 15–16 years.[1]
In India, the issue assumes particular significance because drug dependence can
affect education, employment, family relationships, physical and mental
well-being and social integration.
India's
principal legislative response is the Narcotic Drugs and Psychotropic
Substances Act, 1985 (NDPS Act). The statute was enacted to consolidate and
amend the law relating to narcotic drugs and psychotropic substances, provide
stringent controls over their production, possession, trafficking and related
activities, and implement India's international obligations concerning narcotic
drugs and psychotropic substances.[2]
The Act therefore primarily represents a prohibition-and-enforcement model,
although its framework also contains provisions directed towards prevention,
treatment and rehabilitation.³
The
stringent character of the NDPS framework is understandable in view of the
devastating consequences of organised drug trafficking. Nevertheless, the legal
question becomes more complex when the person involved is a young individual
suffering from substance dependence rather than a trafficker or commercial
supplier. Treating all drug-related conduct principally through criminal law
may inadequately distinguish between organised illicit drug activity and drug
dependence as a health and social problem. This distinction forms the central
premise of the present study.
NDPS Act and the Emerging Public-Health Approach
The
Indian legal framework has gradually recognised that drug control cannot depend
exclusively upon criminal enforcement. Section 4 of the NDPS Act requires the
Central Government to take measures for preventing and combating the abuse of
narcotic drugs and psychotropic substances and illicit traffic therein.[3]
The Act also establishes the National Fund for Control of Drug Abuse,
demonstrating that the legislative framework contains a preventive and
rehabilitative dimension alongside its punitive provisions.[4]
This
broader orientation is reflected in India's National Action Plan for Drug
Demand Reduction (NAPDDR). The Government's approach includes preventive
education, awareness generation, identification, counselling, treatment,
rehabilitation and capacity building.[5]
The programme also provides for Integrated Rehabilitation Centres for Addicts,
Community-Based Peer-Led Intervention programmes, Outreach and Drop-In Centres,
District De-Addiction Centres and Addiction Treatment Facilities. The Nasha
Mukt Bharat Abhiyaan, launched in 2020 and subsequently expanded nationwide,
specifically focuses on educational institutions, youth, identification of
persons affected by substance dependence, counselling and treatment.[6]
Government
data further demonstrates the scale of this preventive approach. By March 2025,
the Nasha Mukt Bharat Abhiyaan had reportedly reached more than 4.96 crore
young people, while government-supported rehabilitation infrastructure included
approximately 350 Integrated Rehabilitation Centres for Addicts.[7]
These initiatives indicate that India has already moved, at least
institutionally, beyond a purely punitive understanding of drug abuse. The
policy challenge is therefore not simply whether India should have a
public-health model, but how far the existing public-health components should
be integrated into and potentially reshape the criminal-law framework.
Need for a Balanced Youth-Centred Model
The
debate concerning the sufficiency of the NDPS Act should not be understood as a
choice between abandoning criminal law and completely decriminalising drugs.
Organised trafficking, illicit manufacture, financing and commercial
distribution present serious threats to public safety and require effective
criminal enforcement. The central question is whether the same punitive
orientation should dominate responses to young persons whose principal problem
is dependency, repeated consumption or vulnerability to substance abuse.
A
public-health model would place greater emphasis on early prevention,
confidential counselling, accessible treatment, rehabilitation, relapse
prevention, social reintegration and reduction of stigma. India's existing
NAPDDR already recognises the importance of counselling, treatment and
rehabilitation and seeks to reduce the stigma and discrimination associated
with substance dependence.[8]
This provides an institutional foundation upon which a more comprehensive
youth-centred model could be developed.
The
constitutional dimension is equally important. Article 21 of the Constitution
protects life and personal liberty and has been judicially interpreted to
encompass dimensions of health, dignity and humane treatment.[9]
A drug-policy framework affecting young people must therefore balance the
State's legitimate interest in preventing illicit drug trafficking with the
individual's dignity, rehabilitation and prospects of social reintegration. The
present study accordingly examines whether the NDPS Act, in its existing form,
provides an adequate and proportionate response to youth drug abuse or whether
India should move towards a more integrated public-health model, retaining
strong criminal sanctions for trafficking while strengthening treatment and
rehabilitation for persons affected by drug dependence.
The
central argument advanced in this research is that effective drug control
requires both supply-side enforcement and demand-side health interventions. The
NDPS Act remains essential for combating organised drug markets, but its
effectiveness in addressing youth drug abuse should be evaluated against
broader objectives of prevention, treatment, rehabilitation and human dignity.
A balanced legal framework can therefore protect society from illicit
trafficking while treating dependent young persons primarily as individuals
requiring appropriate health and social interventions rather than relying
predominantly upon punishment.
Research objectives
1. To
critically examine the adequacy of the NDPS Act, 1985 in addressing drug abuse
among youth in India from a criminal-law and constitutional perspective.
2.
To evaluate the feasibility of adopting a public-health-oriented model
integrating prevention, treatment, rehabilitation and harm reduction while
retaining stringent measures against drug trafficking.
Research methodology
The
present study adopts a doctrinal and analytical legal research methodology to
examine the adequacy of the Narcotic Drugs and Psychotropic Substances Act,
1985 in addressing drug abuse among youth and to evaluate the feasibility of a
public-health-oriented approach in India. The study relies primarily on
secondary sources, including the NDPS Act, relevant rules, the Constitution of
India, judicial decisions, government policies, reports and official data
concerning drug abuse and demand reduction. Particular attention is given to
the National Action Plan for Drug Demand Reduction (NAPDDR), Nasha Mukt Bharat
Abhiyaan and rehabilitation mechanisms. International materials and comparative
approaches to drug policy are also examined to identify alternative models of
prevention, treatment and rehabilitation. Relevant books, journal articles,
research papers and authoritative online sources constitute supplementary
materials. The research employs a critical and comparative analytical approach
to assess criminalisation, proportionality, rehabilitation, youth protection
and public health, and ultimately proposes legal and policy measures for
achieving a balanced drug-control framework.
Analysis
1. Adequacy
of the NDPS Act in Addressing Youth Drug Abuse
The
first objective of the study is to critically examine whether the Narcotic
Drugs and Psychotropic Substances Act, 1985 (NDPS Act) is adequate to address
drug abuse among youth from criminal-law and constitutional perspectives. The
analysis demonstrates that the NDPS Act was deliberately enacted as a stringent
control statute. Its principal objective is to regulate narcotic drugs and
psychotropic substances, prevent illicit trafficking and impose serious
sanctions for prohibited activities. The Supreme Court in State of Punjab v.
Baldev Singh recognised the stringent nature of the statute and emphasised
that, because the legislation imposes severe consequences, statutory safeguards
must be strictly observed.[10]
The Court's reasoning is particularly relevant to young persons because a
criminal conviction under the NDPS framework may have consequences extending
beyond imprisonment, including educational disruption, employment difficulties
and social stigma.
At
the same time, the NDPS Act does not create an entirely punitive framework.
Section 27 specifically provides a comparatively lesser punishment for
consumption or possession of small quantities intended for personal
consumption, while Section 64A provides immunity from prosecution in specified
circumstances to addicts who voluntarily undergo de-addiction treatment.[11]
These provisions demonstrate that Parliament has recognised a distinction
between drug trafficking and personal drug dependence. The existence of Section
64A is especially significant to the present research because it provides a
statutory foundation for moving towards a public-health-oriented response
without abandoning the NDPS framework altogether.
The
Supreme Court's decision in Gaunter Edwin Kircher v. State of Goa illustrates
the importance of correctly identifying personal consumption. The Court
modified a conviction under the more serious provision and applied Section 27
where the factual circumstances supported personal consumption involving a
small quantity.[12]
Similarly, in P.P. Beeran v. State of Kerala, the Supreme Court afforded the
accused an opportunity to advance a defence under Section 27, expressly
referring to the legislative benefit available to persons possessing small
quantities for personal consumption.[13]
These decisions indicate that judicial interpretation has occasionally
moderated the harsh consequences of the statute where the facts demonstrate
personal consumption rather than commercial activity.
2. Distinguishing
Users from Traffickers: Judicial Approach
The
distinction between a consumer/addict and a trafficker is central to evaluating
whether criminalisation is an adequate response to youth drug abuse. In Basheer
@ N.P. Basheet v. State of Kerala, the Supreme Court examined Section 27 and
explained the significance of establishing that a small quantity was intended
for personal consumption rather than sale or distribution.[14]
The decision demonstrates that the statutory framework already contains a
differentiated approach, but the burden placed upon an accused to establish
personal consumption may nevertheless create difficulties for vulnerable
persons who lack legal assistance or who are unfamiliar with the evidentiary
requirements.
In
Ayub Khan v. State of Rajasthan, the Court again considered whether the
evidence established personal consumption for the purpose of Section 27.[15]
The case demonstrates the practical importance of evidence concerning addiction
and personal use in determining the appropriate statutory response. Such cases
are particularly relevant to youth because young users may be found in
possession of relatively small quantities in circumstances that do not
necessarily indicate participation in organised trafficking.
A
more recent illustration is Directorate of Revenue Intelligence v. Raj Kumar
Arora (2025), where the Supreme Court considered Section 27 in the context of a
small quantity of a psychotropic substance allegedly intended for personal
consumption. The Court accepted that the factual circumstances, including
possession of syringes, could support an inference of personal use and altered
the conviction accordingly.[16]
The decision is important because it reinforces the proposition that the legal
response should differentiate between personal consumption and commercial drug
activity.
The
same principle is visible in Rijesh Ravindran v. Union of India, where the
Karnataka High Court considered an accused who claimed addiction and personal
consumption and referred to Section 64A's treatment-oriented mechanism.[17]
Although this is a High Court decision rather than a Supreme Court precedent,
it demonstrates an emerging judicial understanding that persons affected by
addiction may require a different legal response from persons engaged in
trafficking.
3. Constitutional
Safeguards, Fair Procedure and Proportionality
The
second dimension of the first objective concerns constitutional protection. The
NDPS Act operates within the constitutional framework of Articles 14 and 21.
Article 14 requires equality before law, while Article 21 protects life and
personal liberty. In Baldev Singh, the Supreme Court stressed that strict
compliance with statutory safeguards is especially important where legislation
imposes severe punishment.[18]
The Court's approach establishes that strong drug-control legislation cannot
operate independently of fair-trial principles.
The
Court's approach in State of Punjab v. Balbir Singh and subsequently in Baldev
Singh regarding search and seizure safeguards is particularly important.
Section 50 safeguards were treated as mandatory in the circumstances addressed
by the Court, reflecting the principle that the severity of the statutory
regime must be accompanied by corresponding procedural protections.[19]
For young accused persons, who may have limited knowledge of legal rights,
procedural safeguards are especially important.
The
Supreme Court's decision in Union of India v. Mohanlal further demonstrates the
Court's insistence upon procedural reliability in NDPS investigations,
particularly concerning seizure, sampling and preservation of seized narcotic
substances.[20]
The case demonstrates that the effectiveness of criminal enforcement depends
upon reliable investigative procedures rather than simply upon the severity of
statutory punishment.
The
proportionality question is therefore central. Where the accused is a
large-scale trafficker, severe criminal sanctions may be justified by the
threat posed to society. Where the accused is a young person suffering from
dependence and involved principally in personal consumption, a
punishment-centred approach may produce limited preventive benefit while
increasing social exclusion. The law must therefore distinguish between harm
caused by trafficking and vulnerability associated with dependence.
4. Existing
Public-Health Elements within the NDPS Framework
The
research demonstrates that the proposition that India must completely replace
criminal law with a public-health model is unnecessarily binary. The NDPS Act
already contains elements of a public-health approach. Section 64A provides
immunity in specified circumstances for addicts who voluntarily undergo
treatment, while Section 71 empowers the Government to establish centres for
identification, treatment, education, after-care, rehabilitation and social
reintegration of persons dependent on narcotic drugs or psychotropic
substances.[21]
Thus, the statutory framework itself recognises treatment and rehabilitation as
legitimate components of drug control.
The
National Action Plan for Drug Demand Reduction (NAPDDR) further strengthens
this approach by providing for preventive education, counselling, treatment,
rehabilitation and social reintegration.[22]
Government-supported mechanisms include Integrated Rehabilitation Centres for
Addicts, District De-Addiction Centres, Addiction Treatment Facilities and
community-based intervention programmes. This demonstrates that India's
drug-control policy already incorporates public-health elements, although these
mechanisms need stronger integration with criminal justice.
The
Nasha Mukt Bharat Abhiyaan similarly places emphasis on awareness, prevention,
treatment and rehabilitation, particularly among young people. The Government
has reported extensive outreach to youth and educational institutions through
the programme.[23]
The existence of these programmes suggests that the appropriate policy question
is not whether India should choose criminal law or public health, but how the
two systems can be better integrated.
5. Significant
Judicial Decisions and Their Relevance
|
Case
|
Principal Legal Issue
|
Relevance to Present Study
|
|
State of Punjab v. Balbir Singh, (1994) 3 SCC 299
|
Search and seizure safeguards
|
Protects accused against procedural abuse
|
|
Gaunter Edwin Kircher v. State of Goa, (1993) 3 SCC 145
|
Small quantity/personal consumption
|
Supports differentiated treatment
|
|
State of Punjab v. Baldev Singh, (1999) 6 SCC 172
|
Section 50 safeguards
|
Emphasises fair procedure
|
|
P.P. Beeran v. State of Kerala (2001)
|
Section 27 defence
|
Recognises statutory benefit for personal users
|
|
Ayub Khan v. State of Rajasthan (2002)
|
Personal consumption
|
Examines evidence concerning user status
|
|
Basheer @ N.P. Basheet v. State of Kerala (2004)
|
Section 27
|
Distinguishes personal use from distribution
|
|
Mohan Lal v. State of Rajasthan (2015)
|
Conscious possession
|
Clarifies mental element in possession
|
|
Union of India v. Mohanlal (2016)
|
Sampling/seizure procedure
|
Strengthens evidentiary safeguards
|
|
Rijesh Ravindran v. Union of India (2021)
|
Addiction and Section 64A
|
Illustrates treatment-oriented judicial reasoning
|
|
Directorate of Revenue Intelligence v. Raj Kumar Arora (2025)
|
Personal consumption
|
Supports differentiated punishment
|
|
Great Legalisation Movement India v. Union of India (2026)
|
Cannabis/drug policy
|
Recent judicial consideration of statutory drug-control
framework
|
Source: Compiled by the researcher
from Supreme Court and High Court decisions concerning the NDPS Act.
The
cases collectively demonstrate that Indian courts have not treated the NDPS Act
as an inflexible punitive instrument. Judicial decisions have repeatedly
considered quantity, personal consumption, possession, procedural safeguards,
treatment and the circumstances of the accused. The jurisprudence therefore
provides a foundation for developing a more differentiated response to youth
drug abuse.
6. Towards
a Public-Health Model for Youth
The
analysis of the second objective indicates that India should move towards a
hybrid public-health and criminal-justice model, rather than completely
abandoning the NDPS Act. Trafficking, manufacture, organised distribution,
financing of illicit drug markets and activities conducted for commercial
profit should continue to attract stringent criminal enforcement. However,
young persons affected by addiction or found in circumstances indicating
personal consumption should increasingly be directed towards assessment,
counselling, voluntary treatment and rehabilitation.
Section
64A already provides a statutory basis for this approach. Its importance lies
in recognising that treatment can be an alternative to prosecution in specified
cases.[24]
The provision could be strengthened through clearer procedures for identifying
eligible addicts, improved coordination between courts and de-addiction
institutions, and greater availability of treatment facilities.
A
public-health model should additionally incorporate early intervention, school
and university prevention programmes, family counselling, mental-health
support, peer-led interventions, relapse prevention and social reintegration.
The objective should not simply be to prevent possession or consumption but to
reduce the underlying conditions that contribute to repeated drug use.
The
research therefore finds that the NDPS Act is necessary but not sufficient. It
remains indispensable for supply-side control and organised trafficking, but
criminal law alone cannot adequately address addiction among young persons. The
jurisprudence of the Indian courts, particularly the recognition of personal
consumption, procedural safeguards and treatment-oriented provisions, already
permits movement towards a more balanced approach.
Finding and discussion
The
doctrinal analysis ultimately supports a rights-based, proportionate and
public-health-centred model. India's existing framework should not be
discarded; instead, it should be recalibrated according to the nature of the
conduct and the circumstances of the individual. The strongest criminal
response should remain directed towards traffickers and organised drug
networks, while young users and persons suffering from dependence should
receive greater opportunities for treatment and rehabilitation.
Such
an approach would also be consistent with the constitutional values of dignity,
equality and personal liberty. The Supreme Court's insistence upon procedural
safeguards in Baldev Singh, together with the statutory recognition of
treatment under Sections 64A and 71, indicates that India's legal framework
already contains the foundations for this transition. The principal requirement
is therefore effective implementation and integration.
The
study consequently concludes that India should not choose between “punishment”
and “public health” as mutually exclusive alternatives. Instead, the future of
Indian drug policy should involve strong supply-side criminal enforcement
combined with a substantially stronger demand-side public-health response. For
youth drug abuse, this model would better reconcile public safety with
rehabilitation, reduce stigma and improve the prospects of long-term social
reintegration.
Conclusion
The
present study concludes that the Narcotic Drugs and Psychotropic Substances
Act, 1985 (NDPS Act) remains an essential component of India’s legal response
to illicit drugs, particularly for controlling trafficking, commercial
distribution, organised drug networks and the illegal manufacture of narcotic
substances. However, the analysis demonstrates that criminalisation alone is
insufficient to address drug abuse among youth. Young persons affected by
substance dependence often require prevention, counselling, treatment,
rehabilitation and social reintegration rather than a predominantly punitive
response.
The
NDPS Act itself contains the foundations of a public-health approach through
provisions such as Section 64A, which provides specified immunity from
prosecution for addicts voluntarily undergoing de-addiction treatment, and
Section 71, which enables the establishment of treatment and rehabilitation
centres. Judicial decisions have also demonstrated the importance of
distinguishing personal consumption from commercial trafficking and ensuring
procedural safeguards under the Act.
Accordingly,
India should not completely replace the NDPS framework but should adopt a
balanced hybrid model. Traffickers and organised drug networks should continue
to face stringent criminal sanctions, while young users and persons suffering
from addiction should have greater access to treatment-oriented interventions.
Prevention programmes in schools and universities, accessible de-addiction
facilities, counselling, family support, relapse prevention and rehabilitation
should be strengthened.
Ultimately,
India's drug policy should move from a predominantly punishment-centred
approach towards a proportionate, rights-based and public-health-oriented
framework, thereby protecting society while preserving the dignity, health and
rehabilitation prospects of young people.
Suggestions
1.
Adopt a balanced public-health
and criminal-justice model for addressing youth drug abuse while retaining
stringent measures against trafficking and organised drug networks.
2.
Prioritise treatment over
punishment for young persons involved primarily in personal consumption or
suffering from substance dependence.
3.
Strengthen implementation of
Section 64A of the NDPS Act by facilitating access to voluntary de-addiction
and treatment programmes.
4.
Expand youth-focused prevention
programmes in schools, colleges and universities through evidence-based drug
education and awareness campaigns.
5.
Increase accessible
de-addiction and rehabilitation facilities, particularly in rural, semi-urban
and economically disadvantaged areas.
6.
Develop specialised counselling
and family-support services to address psychological, social and familial
factors contributing to drug dependence.
7.
Establish coordinated referral
mechanisms connecting courts, police, healthcare institutions, rehabilitation
centres and social-welfare agencies.
8.
Ensure proportionality and
constitutional safeguards in investigation, arrest, prosecution and sentencing
under the NDPS Act.
9.
Strengthen post-treatment
rehabilitation and social reintegration through education, vocational training,
employment assistance and community support.
10.
Maintain stringent enforcement
against trafficking and organised crime, while adopting a more rehabilitative
approach towards vulnerable young users.
Future scope
Future
research may empirically examine the effectiveness of the NDPS Act in
addressing youth drug abuse across Indian states. Comparative studies could
evaluate criminal-justice and public-health models, including decriminalisation
and harm-reduction approaches. Further research may assess rehabilitation
outcomes, judicial practices, treatment accessibility and the effectiveness of
Section 64A.
References
1.
United Nations
Office on Drugs & Crime, World Drug Report 2025: Methodological Annex,
at 19 (2025), UNODC World Drug Report (last visited Aug. 5, 2026). (unodc.org)
2.
Narcotic Drugs and Psychotropic
Substances Act, No. 61 of 1985, pmbl.
(India), India Code (last visited Aug. 6, 2026). (indiacode.nic.in)
3.
Id. § 4.
4.
Id. § 7A.
5.
Ministry of Soc.
Just. & Empowerment, Gov't of India, National Action Plan for Drug
Demand Reduction, NAPDDR (last visited Aug. 7, 2026). (socialjustice.gov.in)
6.
Id.; Press
Information Bureau, Ministry of Soc. Just. & Empowerment, Gov't of India, Ministry
of Social Justice and Empowerment Has Launched the National Action Plan for
Drug Demand Reduction (Aug. 1, 2023), PIB
(last visited Aug. 8, 2026). (pib.gov.in)
7.
Press Information
Bureau, Ministry of Home Affairs, Gov't of India, Measures to Prevent Drug
Abuse and Combat Illegal Drug Trade (Mar. 18, 2025), PIB
(last visited Aug. 9, 2026). (pib.gov.in)
8.
Ministry of Soc.
Just. & Empowerment, Gov't of India, National Action Plan for Drug
Demand Reduction, supra note 6.
9.
INDIA CONST. art. 21.
10. State of
Punjab v. Baldev Singh, (1999) 6 SCC
172.
11. Narcotic Drugs & Psychotropic Substances Act, No.
61 of 1985, §§ 27, 64A (India).
12. Gaunter
Edwin Kircher v. State of Goa,
(1993) 3 SCC 145.
13. P.P. Beeran
v. State of Kerala (2001).
14. Basheer @
N.P. Basheet v. State of Kerala
(2004).
15. Ayub Khan
v. State of Rajasthan (2002).
16. Directorate
of Revenue Intelligence v. Raj Kumar Arora,
Crim. App. No. 1319 of 2013 (S.C. Apr. 17, 2025).
17. Rijesh
Ravindran v. Union of India
(Karn. H.C. July 28, 2021).
18. Baldev
Singh, (1999) 6 SCC 172.
19. State of
Punjab v. Balbir Singh, (1994) 3 SCC
299; Baldev Singh, (1999) 6 SCC 172.
20. Union of
India v. Mohanlal, (2016) 3 SCC
379.
21. Narcotic Drugs & Psychotropic Substances Act, No.
61 of 1985, §§ 64A, 71 (India).
22. Ministry of Social Justice & Empowerment, Gov't of
India, National Action Plan for Drug Demand Reduction.
23. Press Information Bureau, Gov't of India, Measures
to Prevent Drug Abuse and Combat Illegal Drug Trade (Mar. 18, 2025).
24. Narcotic Drugs & Psychotropic Substances Act, No.
61 of 1985, § 64A (India).
[1] United Nations Office on Drugs
& Crime, World Drug Report 2025: Methodological Annex, at 19
(2025), UNODC World
Drug Report (last
visited Aug. 5, 2026). (unodc.org)
[2] Narcotic Drugs and
Psychotropic Substances Act, No. 61 of 1985, pmbl. (India), India Code (last visited Aug. 6, 2026). (indiacode.nic.in)
[3] Id. § 4.
[4] Id. § 7A.
[5] Ministry of Soc. Just. &
Empowerment, Gov't of India, National Action Plan for Drug Demand Reduction,
NAPDDR (last visited Aug. 7, 2026). (socialjustice.gov.in)
[6] Id.; Press Information Bureau,
Ministry of Soc. Just. & Empowerment, Gov't of India, Ministry of
Social Justice and Empowerment Has Launched the National Action Plan for Drug
Demand Reduction (Aug. 1, 2023), PIB (last visited Aug. 8, 2026). (pib.gov.in)
[7] Press Information Bureau, Ministry
of Home Affairs, Gov't of India, Measures to Prevent Drug Abuse and Combat
Illegal Drug Trade (Mar. 18, 2025), PIB (last visited Aug. 9, 2026). (pib.gov.in)
[8] Ministry of Soc. Just. &
Empowerment, Gov't of India, National Action Plan for Drug Demand Reduction,
supra note 6.
[9] INDIA CONST. art.
21.
[10] State of Punjab v. Baldev
Singh, (1999) 6 SCC 172.
[11] Narcotic Drugs & Psychotropic
Substances Act, No. 61 of 1985, §§ 27, 64A (India).
[12] Gaunter Edwin Kircher v. State
of Goa, (1993) 3 SCC 145.
[13] P.P. Beeran v. State of Kerala
(2001).
[14] Basheer @ N.P. Basheet v.
State of Kerala (2004).
[15] Ayub Khan v. State of
Rajasthan (2002).
[16] Directorate of Revenue
Intelligence v. Raj Kumar Arora, Crim. App. No. 1319 of 2013 (S.C. Apr.
17, 2025).
[17] Rijesh Ravindran v. Union of
India (Karn. H.C. July 28, 2021).
[18] Baldev Singh, (1999) 6
SCC 172.
[19] State of Punjab v. Balbir
Singh, (1994) 3 SCC 299; Baldev Singh, (1999) 6 SCC 172.
[20] Union of India v. Mohanlal,
(2016) 3 SCC 379.
[21] Narcotic Drugs & Psychotropic
Substances Act, No. 61 of 1985, §§ 64A, 71 (India).
[22] Ministry of Social Justice &
Empowerment, Gov't of India, National Action Plan for Drug Demand Reduction.
[23] Press Information Bureau, Gov't of
India, Measures to Prevent Drug Abuse and Combat Illegal Drug Trade
(Mar. 18, 2025).
[24] Narcotic Drugs & Psychotropic
Substances Act, No. 61 of 1985, § 64A (India).
How to Cite This Article
Prakhar Jaiswal, DRUG ABUSE AMONG YOUTH: IS THE NDPS ACT SUFFICIENT OR SHOULD INDIA SHIFT TOWARDS A PUBLIC HEALTH MODEL?., White Black Legal – International Law Journal, ISSN: 2581-8503, Vol. 4, Issue 1, September 2026, pp. 479-495, DOI Link: https://www.doi-ds.org/doilink/09.2026-77435294/DRUG ABUSE AMONG YOUTH: IS THE NDPS ACT SUFFICIENT. Available at: https://www.whiteblacklegal.co.in/public/details/drug-abuse-among-youth-is-the-ndps-act-sufficient-or-should-india-shift-towards-a-public-health-model
Author & Publication Record
Authors: Prakhar Jaiswal
Registration ID: 107073 | Published Paper ID: WBL7073
Year: Sep- 2026 | Volume: 4 | Issue: 1
Approved ISSN: 2581-8503 | Country: Delhi, India
Page No.: 479-495
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