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M/s Cheminova India Ltd. v. The State of Punjab

Criminal Appeal · 2021 INSC 381Decided 4 Aug 2021
Criminal Appeal No. 749 of 2021
Justice Navin Sinha · Justice R. Subhash Reddy

Background

An Insecticide Inspector inspected a dealer's premises in Amritsar in 2011 and seized samples of insecticide manufactured by the appellant-company, which upon laboratory analysis were found to contain a lower percentage of active ingredient than labelled (34.70% against a declared 40%), amounting to "misbranding." A criminal complaint was filed against the company and its officers in March 2014. The Punjab & Haryana High Court declined to quash the complaint against the appellants (while quashing it against one co-accused), prompting this appeal.

Decision Breakdown

The Supreme Court held that the complaint was barred by limitation. Under Section 469 CrPC, the three-year limitation period for this offence began running from 14.03.2011, the date the first (Ludhiana) laboratory report confirmed misbranding, not from the later date of a second confirmatory test at Faridabad requested by the company. Since the complaint was filed on 25.03.2014, more than three years after the original report, it was time-barred. The Court allowed the appeal, set aside the High Court's order, and quashed the complaint.

Lesson Learnt

The clock for filing a criminal complaint starts from the date the offence (and the evidence confirming it) first comes to light: a party's own request for re-testing or a second opinion does not reset or extend that limitation period for the prosecution.

Official source (sci.gov.in)View Judgment (PDF)

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