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Nagarajan v. The State of Tamil Nadu

Criminal Appeal · 2025 INSC 703Decided 15 May 2025
Crl.A. No.-001390-001390 - 2025
Justice Dipankar Datta · Justice Manmohan

Background

This judgment jointly decided two unrelated criminal appeals raising the same legal question. In the lead case, a curd sample taken from a shop run by Nagarajan and a co-accused in 2001 was found adulterated under the Prevention of Food Adulteration Act (PoFA Act), leading to their conviction and a six-month sentence, upheld by the trial court, appellate court, and the Madras High Court. In the connected case, one Naresh Chandra was similarly convicted in 1987 for obstructing a Food Inspector from taking a sample of goods he was selling, with his conviction upheld through the Allahabad High Court. Both sets of appellants argued that Section 20AA of the PoFA Act, which bars courts from granting the benefit of probation (a suspended/non-custodial sentence for first-time offenders), was unconstitutional and outdated.

Decision Breakdown

The Supreme Court held that Section 20AA validly excludes probation for PoFA Act offences committed while that provision was in force (1976 to its 2006 repeal), and rejected the constitutional challenge. However, the Court found that once the PoFA Act was repealed and replaced by the Food Safety and Standards Act, 2006, the strict bar on probation no longer serves any continuing purpose, and, following its own precedent, chose to convert the prison sentences into fines instead, given how many decades had passed since the original offences. The lead appeal was allowed in part due to inconsistencies in the sample analysis reports, and the connected appeal was also partly allowed in the interest of justice, even though the Bench expressed some disagreement with the reasoning of an earlier coordinate-bench ruling it chose to follow for consistency.

Lesson Learnt

Even when a law technically permits only imprisonment, appellate courts retain the discretion (especially decades after minor, non-violent regulatory offences) to convert a prison sentence into a monetary fine in the interest of justice, particularly where the underlying law has since been repealed or updated.

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

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