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  • The Supreme Court observed that the offence of Criminal Conspiracy under Section 120B of the Indian Penal Code requires some kind of physical manifestation of agreement to commit an offence. 
  • In this case, all of the accused were employees of the Central Bank of India's Guna Branch, and they were charged with theft (of Rs. Six Lakhs from the Bank's safe and strong room), house trespass, destruction of valuable security, and other offences. 
  • The appellant-accused was convicted concurrently for offences under Sections 201, 380, 435, 457, and 477 of the Indian Penal Code, 1860, as well as Section 120B.
  • The appellant was the Head Cashier and was in possession of one of the keys to the Bank's dual locker system for the safe custody of cash and valuable security.
  • The Supreme Court bench of Justices BR Gavai and PS Narasimha noted in the appeal that the main ingredient of the offence of criminal conspiracy under Section 120B of the IPC is an agreement to commit an offence. 
  • Using evidence on record, the court determined that the prosecution had failed to produce any evidence to satisfy the Court that there was a prior meeting of minds between the Appellant and the other accused.
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