Food Adulteration Case: Supreme Court Quashes Prosecution for Barcode Compliance

The Supreme Court of India, in the case of Raghav Gupta vs. State (NCT of Delhi) & Another, delivered a crucial judgment concerning the prosecution under the Prevention of Food Adulteration Rules, 1955. The case revolved around an alleged violation of labeling requirements under Rule 32(e) regarding the declaration of lot/batch numbers on imported beverage products.

The Court held that continuing prosecution when all necessary details were available in the barcode would be an abuse of the legal process, causing unnecessary harassment to the appellant.

Background of the Case

The case originated when the Food Inspector purchased sealed samples of Snapple Juice Drink on May 3, 2011, for analysis. The Public Analyst’s report dated May 30, 2011, confirmed that the sample met food standards but was misbranded due to the lack of a lot/batch number declaration, violating Rule 32(e) of the Prevention of Food Adulteration Rules, 1955.

The appellant, Raghav Gupta, was a director of M/s V & V Beverages Pvt. Ltd., which imported the drink from the foreign manufacturer, Schweppes International Rye Brook. The product was duly cleared by Indian Customs.

Legal Issues and Arguments

The key legal issues in this case were:

• Whether the product was misbranded under Rule 32(e) due to the absence of a printed lot/batch number.
• Whether prosecution was justified when all required information was available in the barcode.
• Whether the failure to consider the barcode as a valid means of labeling violated principles of fairness.

Arguments by the Petitioner (Raghav Gupta)

The petitioner, represented by Senior Counsel Ms. Geeta Luthra, argued:

• The product contained a barcode that stored all relevant details, including batch number and lot identification.
• The barcode could be scanned to retrieve the required information, satisfying Rule 32(e).
• Allowing prosecution despite technological compliance with labeling norms amounted to legal harassment.
• Multiple authorities, including Customs, had cleared the product for import without objections.

Arguments by the State (NCT of Delhi)

The respondent, represented by Additional Solicitor General Mr. Jayant K. Sud, argued:

• Rule 32(e) required a visible printed declaration of lot/batch numbers.
• Merely encoding the information in a barcode without an accompanying printed declaration did not comply with the law.
• Ensuring visible printed details was essential for consumer protection and regulatory oversight.

Supreme Court’s Ruling

On Compliance with Rule 32(e)

The Supreme Court observed that:

• The presence of a barcode with all necessary product information satisfied the intent of Rule 32(e).
• Modern technological methods, such as barcode labeling, must be recognized in regulatory compliance.
• Rigid insistence on a printed declaration, despite barcode availability, was unreasonable.

On Abuse of Legal Process

The Court emphasized that:

• Continuing prosecution despite clear barcode compliance would waste judicial resources.
• The case had dragged on for nearly a decade without material benefit.
• The failure of the authorities to acknowledge barcode labeling indicated a lack of adaptation to technological advancements.

On Quashing of Proceedings

Given these findings, the Court ruled that:

• The prosecution was an abuse of process and caused undue harassment.
• The proceedings in CC No. 04 of 2012 before the ACMM-2, Patiala House Court, New Delhi, were quashed.
• All charges against the appellant were dismissed.

Legal Principles Established

This ruling reinforces several key legal principles:

• Recognition of Technological Compliance: Modern methods such as barcode labeling should be acknowledged in regulatory compliance.
• Preventing Frivolous Prosecutions: Courts must intervene to prevent harassment due to outdated regulatory interpretations.
• Judicial Economy: Prosecutions that serve no practical purpose must be quashed to prevent judicial waste.

Conclusion

The Supreme Court’s decision in Raghav Gupta vs. State (NCT of Delhi) is a landmark judgment that protects businesses from arbitrary prosecution over technical compliance issues. By recognizing barcode labeling as sufficient compliance under Rule 32(e), the Court has ensured that legal frameworks evolve with technology.

This ruling serves as an important precedent in consumer protection and regulatory enforcement, reaffirming the need for balanced and practical interpretations of labeling laws.

Petitioner Name: Raghav Gupta.
Respondent Name: State (NCT of Delhi) & Another.
Judgment By: Justice R.F. Nariman, Justice Navin Sinha, Justice Indira Banerjee.
Place Of Incident: New Delhi.
Judgment Date: 04-09-2020.

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