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Prem Chand v. State of Haryana

Criminal Appeal · 2020 INSC 471Decided 30 Jul 2020
Criminal Appeal No. 2255 of 2010
Justice N.V. Ramana · Justice Surya Kant · Justice Krishna Murari

Background

In 1982, a Food Inspector seized a sample of turmeric (Haldi) powder from Prem Chand's shop, which a public analyst's report said contained live insects and worms. The trial court acquitted him in 1995, but 14 years later, in 2009, the Punjab and Haryana High Court reversed the acquittal and convicted him under the Prevention of Food Adulteration Act for selling adulterated food and selling without a licence.

Decision Breakdown

The Supreme Court restored the acquittal. It found that the Medical Officer present at the time of seizure did not himself observe any insects in the sample with the naked eye, that there was an unexplained 18-day gap between dispatch and analysis with no proof the sample had not been tampered with in that time, and, most importantly, that the public analyst's report never certified the sample as "insect-infested" or "unfit for human consumption," a specific finding the law requires for a conviction under the relevant provision. With these gaps, the Court held the prosecution had failed to prove its case and set aside the High Court's conviction.

Lesson Learnt

In food-adulteration cases, a lab report noting contamination is not automatically enough for conviction: the law requires the report to expressly state the sample was unfit for human consumption, and any break in the chain of custody of the sample can create reasonable doubt that benefits the accused, even decades after the alleged offence.

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

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