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