Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Criminal LawSupreme Court of India

M/s Sri Mahavir Agency & Anr. vs. The State of West Bengal & Anr.

Criminal AppealDecided 17 Apr 2023
Criminal Appeal No. 982 of 2023
Abhay S. Oka · Rajesh Bindal

Background

The appellant was a vendor who bought sealed packets of 'Pan Parag' pan masala from manufacturer M/s Kothari Pouches Ltd. and sold them on. Samples collected from a buyer's shop failed quality tests (both by the Municipal Public Analyst and, on appeal, the Central Food Laboratory), and the appellant, impleaded as an accused after the buyers produced his bill, was convicted under the Prevention of Food Adulteration Act, 1954, with the conviction upheld by two lower courts.

Decision Breakdown

The Supreme Court held that Section 19(2) of the Act protects a "vendor" who proves the article was bought from the manufacturer/dealer with a written warranty in the prescribed form (Rule 12A, Form VIA), and that under the proviso to Section 14, an ordinary sale invoice with a warranty-type certification qualifies as such a warranty. The appellant's purchase invoice from the manufacturer carried exactly this certification. The lower courts had failed to consider this statutory defence, so the Court set aside the conviction and discharged the appellant's bail bonds.

Lesson Learnt

A trader who buys packaged food from a licensed manufacturer/dealer with a proper warranty on the invoice cannot be convicted for adulteration later discovered in that product. The law shifts responsibility to the manufacturer who gave the warranty, provided the vendor kept the product in the same condition.

M/s Sri Mahavir Agency & Anr. vs. The State of West Bengal & Anr. – Legal Case Shots | LegalAware