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The State of Uttar Pradesh v. Aman Mittal & Anr.

Criminal Appeal · 2019 INSC 1001Decided 4 Sept 2019
Criminal Appeal Nos. 1328-1329 of 2019
Justice L. Nageswara Rao · Justice Hemant Gupta

Background

Police raided petrol pumps in Lucknow after finding that fuel dispensing machines had been rigged with hidden electronic chips (operated by remote controls) to short-deliver petrol and diesel to customers. An FIR was registered under several IPC sections (including cheating, forgery, and criminal conspiracy) as well as the Essential Commodities Act and weights-and-measures laws, and the accused dealers were arrested and charge-sheeted. The accused approached the High Court under Section 482 CrPC to quash the charges, and the High Court quashed some charges and also made additional directions, including ordering disciplinary action against the investigating officers, prompting the State of U.P. to appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that offences strictly about weight/measure violations (Sections 265 and 267 IPC) could not be separately prosecuted once Section 51 of the Legal Metrology Act applies, since that Act expressly excludes parallel IPC prosecution for the same subject matter, so those specific charges were rightly quashed. However, other charges such as cheating, forgery (Sections 420, 467, 468, 471 IPC) and criminal conspiracy (Section 120-B) are not covered by the Legal Metrology Act's exclusion and could still be prosecuted, since rigging dispensing machines with hidden chips goes beyond a mere weights-and-measures violation. The Court also held that the High Court had exceeded its jurisdiction under Section 482 CrPC by passing directions against the investigating officers (ordering disciplinary action) in a petition that was only about quashing charges against the accused, so those directions were set aside. The appeals were partly allowed accordingly, and a connected appeal involving the same legal question (short-delivery charges at another outlet) was also partly allowed on the same reasoning.

Lesson Learnt

A special law like the Legal Metrology Act can block parallel prosecution under the general Penal Code only for offences that specifically concern weights and measures: more serious allegations like cheating, forgery, or conspiracy can still proceed separately; and a High Court hearing a petition to quash charges cannot use that occasion to pass unrelated punitive directions against investigators who are not before it.

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

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