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

Ram Nath vs. The State of Uttar Pradesh & Ors.

Not available · 2024 INSC 138Decided 21 Feb 2024
Not available
Justice Abhay S. Oka · Justice Sanjay Karol

Background

Several traders and companies (including a mustard oil seller and a cold-drink manufacturer) were facing prosecution under Sections 272 and 273 of the IPC (adulteration and sale of noxious food) for alleged food adulteration, based on FIRs registered after the FSSA came into force on 29 July 2010. Some High Court orders had quashed such FIRs, relying on an Allahabad High Court ruling (the "Pepsico" case) that held the FSSA's Section 89 overriding clause meant only the FSSA, not the IPC, could be used for food-related offences after that date; other High Court orders had refused to quash similar FIRs, creating conflicting outcomes across several appeals which were all heard together.

Decision Breakdown

The Supreme Court held that Section 89 of the FSSA gives it an overriding effect over any other law, not just other "food-related" laws, to the extent of any inconsistency, for matters covered within FSSA's field. Since the FSSA's Section 59 (punishing sale/manufacture of "unsafe food") is a more comprehensive and stringent provision covering the same ground as IPC Sections 272 and 273, offences of food adulteration/sale of noxious food occurring after the FSSA came fully into force must be prosecuted under the FSSA, not the IPC. The Court therefore quashed the IPC prosecutions in the cases where FIRs were registered under Sections 272/273, while leaving it open to authorities to initiate fresh proceedings under the FSSA if not already time-barred; it dismissed the State's appeal that had sought to prosecute under IPC in a similar situation.

Lesson Learnt

When a newer, more specific law is enacted to comprehensively govern an area (like the FSSA for food safety) and contains an overriding clause, it takes precedence over older general laws (like the IPC's food-adulteration provisions) covering the same conduct, so the specific law's own, often stricter: penalties will apply instead.

Ram Nath vs. The State of Uttar Pradesh & Ors. – Legal Case Shots | LegalAware