Showing posts with label food sample. Show all posts
Showing posts with label food sample. Show all posts

Wednesday, 11 November 2015

Whether accused can be discharged in prevention of food adulteration case on the ground that sample of seized food is not available for analysis?

 The second count on which the defence equally must succeed is also a formidable ground. It is apparent, as is clarified from the narration of the prosecution case, that one sample was sent to the Public Analyst at Bombay, while the second sample was sent to the Public Analyst at Pune by the Local Health Authority on the request of the complainant, because the first Report was defective. Thus, the Local Health Authority had in their possession left with only one out of the three samples. The purpose always is that one sample, if demanded, is to be given to the accused, while the second sample is to be retained in the Court where the complaint is filed so that if an occasion arises, that sample can be sent to the Central Food Laboratory at Calcutta, as is permissible under the various provisions of Act and the Rules, including section 13. However, in the instant case only one sample was sent to the Court. It is true that the accused did not exercise his option of moving the Court within ten days from the receipt of the Report for sending the sample to the Central Food Laboratory at Calcutta. However, two things are annexed to this situation. Under sub-section (2) of section 13 of the Act, the accused has a right to move the trial Court within 10 days from the receipt of the Report from the Local Health Authority for sending the sample to the Central Food Laboratory, and under sub-clause (2-A) of section 13 of the Act, the Court had to call upon the Local Health Authority, if such an application is made by the accused, to send one sample to the Court. Under sub-clause (2-B) it is after the receipt of such sample within five days from the Local Health Authority that the Court has to satisfy itself that the sample is received in a sealed condition and there is no tampering or no leakage. This has nexus with the provisions of Rule 14 under which it is prescribed as to how the packing of the sample is to be made by the Food Inspector when the sample is taken from the accused. If the Court is satisfied that the fastening is intact, then it has to forward that sample to the Central Food Laboratory and that Report or Certificate would prevail over the Report of the Public Analyst and would have a conclusive tendency about the evidentiary value. Now, in the instant case it is fully established on evidence that the sample that was with the Local Health Authority was ultimately sent to the Court, though it is not clarified under what circumstances and even though the accused had not applied for the same. Nonetheless it is an accepted position that when that sample was received by the Court, there was apparent leakage which is accepted by the Clerk of the Court examined at the trial and it is conceded by the prosecution that the leakage was on account of the defect in the process of packing and thereby not complying with the provisions of Rule 14. This would also give an additional ground about the prejudice that is being caused to the accused, because in the instant case even if the accused had asked for sending the sample to the Central Food Laboratory at some stage, the purpose would have been frustrated, because the only sample available was in a tampered condition. The prejudice would be, therefore, apparent. This third point has also been correctly dealt with by the learned Magistrate.
Bombay High Court
State Of Maharashtra vs Padmashi Velji Chheda And Ors. on 8 October, 1986
Equivalent citations: 1986 (3) BomCR 534

Bench: V Kotwal
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Tuesday, 10 November 2015

Whether prosecution in prevention of food adulteration case can be quashed on the ground that preservative in sample is used beyond permissible limit?

When it is the case of use of preservative and the preservative is used beyond permissible limit, the aforesaid position of law needs to be kept in mind. The preservative like sulpur dioxide is chemical substance and so, it is up to the accused to show that due to the delay caused in analysis, the sample must have become unfit and sample must have deteriorated due to natural process and so, the quantity of SO 2 used initially cannot be ascertained in such a sample. The Court cannot presume that such change might have occurred. The aforesaid provisions show that the Court is expected to leave such point to the expert. Thus, different cases of food adulteration need to be dealt with differently. In the present case, it can not be presumed that sample must have become unfit on the date of filing of complaints. It was up to the expert to say whether sample had been unfit. In view of this position of law and the facts and circumstances of the case, this Court has Cri. Appln. No. 230/14 & Ors.
no hesitation to observe that the proceedings cannot be quashed and the order of issue process cannot be set aside.
Bombay High Court
Aravind Shankar Manegaonkar vs The State Of Mah on 5 November, 2014
Bench: T.V. Nalawade
Citation; 2015 CRLJ(NOC)482 BOM
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Sunday, 6 September 2015

Whether accused can be acquitted in food adulteration case on the ground that intermediary vessel and spoon used for stirring the sample was not dry and clean?

Rule 14 is mandatory and if it is proved that mandate of this rule is not complied with, accused is 

entitled to acquittal - Not only the container in which the sample of food articles are taken, intermediary vessels, spoon etc. where food articles are handled for mixing, stirring or otherwise for the purpose of sampling also shall be clean and dry.
 The Prevention of Food Adulteration Act was enacted to curb and remedy the widespread evil of food adulteration and to ensure the availability of wholesome food to the people. It is well settled that the language of such a statute should be construed in a manner which would suppress the mischief, advance the remedy, promote the object of the statute, prevent its subtle, evasion and foil its artful circumvention. Dealing with an article of food which is adulterated is punishable under Section 16(i)(a) of the Act. Apex Court has deprecated a narrow and pedantic construction of the Prevention of Food Adulteration Act, 1954 likely to leave the loopholes for the adulterant to escape. (See: Murlidhar v. State of Maharashtra (AIR 1976 SC 1929 at Page 1934 and Kisan v. State of Maharashtra (AIR 1977 SC 435). It is true that in criminal jurisprudence, there is presumption in favour of the innocence of the accused and it is the duty of the prosecution to prove the charges. But when prosecution has proved that sampling was done in accordance with law, it is for the accused to point out regarding the alleged defects in the case and the court has to decide the matter on the totality of evidence. Where there are two presumptions; and both are equally balanced, court must prefer that which is best according to facts and evidence on record. In this case there was not even a suggestion during trial that the intermediary vessel and spoon used for stirring the sample was not dry and clean. In Section 313statement also there is no such case for the accused. DW. 1 also did not state so. PW. 1, Food Inspector, has stated that he has taken the sample in accordance with law. In the absence of cross examination on this point and the evidence to the contrary, the official presumption regarding the regularity of official act can be drawn on the facts and the circumstances of this case. We see no ground to disturb the findings made by the court below in a revision petition.
Kerala High Court
Babu vs Food Inspector on 3 March, 2003
Equivalent citations: 2003 CriLJ 3812, 2003 (2) KLT 90

Bench: J Koshy, A Lekshmikutty
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