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Raghav Gupta v. State (NCT of Delhi)

Criminal Appeal · 2020 INSC 532Decided 4 Sept 2020
Criminal Appeal No. 562 of 2020
Justice Rohinton Fali Nariman · Justice Navin Sinha · Justice Indira Banerjee

Background

A Food Inspector had purchased a sealed sample of "Snapple" Juice Drink in 2011, and the Public Analyst found the sample met quality standards but was "misbranded" because it lacked a printed lot/batch number declaration, as required under Rule 32(e) of the Prevention of Food Adulteration Rules, 1955. A criminal complaint was filed against the appellant, a director of the importing company, and his application for discharge was rejected by both the trial court and the High Court.

Decision Breakdown

The Supreme Court found that the lot/batch/code information required under Rule 32(e) was, in fact, available on the product via a barcode that could be decoded with a standard barcode scanner: a point the State could not rebut. Since the required information was genuinely present (just encoded rather than printed in plain text), the Court held that continuing the prosecution would serve no useful purpose, would amount to an abuse of the legal process, and would cause unnecessary harassment to the appellant. It therefore quashed the prosecution entirely.

Lesson Learnt

A technical or hyper-literal reading of a labelling regulation should not be used to prosecute someone when the substantive information the law requires is actually available (even if conveyed through a different, verifiable medium like a barcode): courts will step in to prevent such abuse of criminal process.

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

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