Supreme Court Acquits Businessman in Food Adulteration Case: Key Legal Insights
In a landmark ruling, the Supreme Court of India overturned the conviction of Hari Shankar Aggarwal in a case involving allegations under the Prevention of Food Adulteration Act, 1954. The decision was significant as it clarified the legal responsibilities of nominees in food-related businesses and set a precedent for corporate liability in similar cases. The judgment was delivered by a three-judge bench comprising Ashok Bhushan, S. Abdul Nazeer, and Hemant Gupta. The case highlighted crucial legal questions regarding liability under food adulteration laws and the procedural requirements for assigning responsibility.
This case revolved around an alleged violation of food safety laws at a commercial establishment named Oswal Traders. The authorities had conducted an inspection at the shop and later filed a case against multiple individuals, including Aggarwal, who was incorrectly identified as the nominee of the firm. The appellant argued that he was never designated as a nominee and that another individual, Devendra Singh Bhadauria, was legally responsible.
Background of the Case
The case originated from an inspection conducted by the Medical and Health Department of Rajasthan on March 2, 2002, at Oswal Traders Shop. The inspection report stated that food products, specifically edible ghee, did not meet the prescribed safety standards. The Commercial Tax Department identified Aggarwal as the nominee of the firm, leading to his prosecution.
The key legal issue was whether Aggarwal could be held accountable under Section 7/16 of the Prevention of Food Adulteration Act, 1954, despite the absence of formal nomination by the Local Health Authority.
Arguments by the Petitioner
The petitioner, represented by senior counsel Mr. Ajay Jain, made the following arguments:
- Aggarwal had never been designated as the official nominee of the firm under food safety regulations.
- The correct nominee, as per official documentation, was Devendra Singh Bhadauria, whose nomination was formally submitted to the Chief Medical Officer, Mathura, on October 21, 1995.
- The prosecution’s reliance on the records from the Commercial Tax Department was misplaced and legally irrelevant, as food safety laws required formal nomination under Section 17 of the Prevention of Food Adulteration Act.
- The document proving Bhadauria’s nomination had been disregarded by the lower courts without sufficient legal reasoning.
Arguments by the Respondent
On behalf of the State of Rajasthan, Dr. Manish Singhvi, senior counsel, presented the following counterarguments:
- The document asserting Bhadauria’s nomination was unreliable and had been dismissed by lower courts.
- The nomination document was printed on the company’s letterhead instead of an official government form, rendering it invalid.
- The trial court had already reviewed the evidence and determined that Aggarwal was liable, leaving no room for the Supreme Court to interfere.
Supreme Court’s Observations
The Supreme Court scrutinized the arguments and found the following key points:
- Paragraph 10 of the complaint identified Aggarwal as the nominee based on tax department records, while Paragraph 11 confirmed that Bhadauria was listed as the director in health department records.
- Section 17 of the Prevention of Food Adulteration Act mandates that nomination be submitted to the Local Health Authority for it to hold legal weight.
- The Supreme Court noted that the official nomination of Bhadauria was received by the health department in 1995, making proceedings against Aggarwal unjustified.
Verbatim Court Ruling
“The averments in the complaint itself clearly indicate that it was the name of Devendra Singh Bhadauria which was with the Local Health Authority. Hence, it was he who was responsible for the affairs of the company and reference of Hari Shankar Aggarwal, whose name was informed by the Commercial Tax Department, has no relevance.”
Final Verdict
The Supreme Court ruled in favor of Aggarwal, stating:
- The orders passed by the lower courts were erroneous and needed to be set aside.
- The proceedings against Aggarwal lacked merit, as there was no legal basis to prosecute him under the Prevention of Food Adulteration Act.
- The Court formally quashed the charges against Aggarwal.
Legal and Practical Implications
This ruling is a crucial precedent in corporate liability cases involving food safety laws. It reinforces that:
- Corporate liability must be attributed to properly nominated individuals rather than individuals arbitrarily identified by tax authorities.
- Formal nomination procedures are critical for ensuring accountability in food safety violations.
- Lower courts must rigorously examine documentary evidence before imposing liability on individuals.
By dismissing the prosecution against Aggarwal, the Supreme Court reinforced the principle that justice should not be compromised by procedural errors or misinterpretations of law.
Petitioner Name: Hari Shankar Aggarwal.Respondent Name: The State of Rajasthan & Anr..Judgment By: Justice Ashok Bhushan, Justice S. Abdul Nazeer, Justice Hemant Gupta.Place Of Incident: Rajasthan.Judgment Date: 10-03-2021.
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