With focus on the recent legal developments, the Food Safety and Standard Authority of India (FSSAI) has emerged as a significant regulatory authority in regard of its power and holding in food adulteration matters. The same has been held and clarified in the case Ram Nath v. State Of Uttar Pradesh (Criminal Appeal No. 472 of 2012) decided by the Hon'ble Supreme Court.
This case has emerged as a turning point, focusing on the evolving dynamics of food related matters within the legal landscape while still focusing on the relevant statutory, judicial provisions and the urgent need for a specialized approach in safeguarding the integrity of the nation's food supply. In this article we aim to elucidate the factual details of the case, focus on the decision held and explore upon the ramifications of the case concerning both legal and societal dimensions.
Ram Nath v. State Of Uttar Pradesh
On May 11th ,2010, the State government of Uttar Pradesh issued an order to initiate prosecutions under Sections 272 and 273 of IPC as well as under the Prevention of Food Adulteration Act, 1954 ('PFA'). On July 28th, 2010, a First Information Report ('FIR') was lodged by a food inspector representing the Regional Food Controller against the appellant (Ram Nath) alleging that he continued to carry on with the business of selling commodity of mustard oil in the absence of a license and adulterated the mustard oil, edible oil and rice bran oil.1 The appellant filed a petition under Section 482 of Criminal Procedure Code, 1973 ('CrPC') seeking to quash prosecution for offences punishable under Sections 272 and 273 of Indian Penal Code (IPC). However, the same was dismissed by the High Court.2 The appellant relied on Pepsico India Holdings (Pvt) Limited v. State of U.P. before the High Court. The High Court in that case held that police had no authority or jurisdiction to investigate a case under the FSSAI and it would have an overriding effect on other food-related laws, including PFA.3 And hence dismissed the petition.
The Hon'ble Apex Court then relied on section 3(zz) of the FSSAI Act which defines "unsafe food" and stated that " the concept of unsafe food is more comprehensive than the concept of adulterated food. Unsafe food means an article of food whose nature, substance or quality is so affected as to render it injurious to health."4
The Supreme Court herein mentioned Section 59 of FSSAI regarding punishment for unsafe food, ranging from 3-month imprisonment to imprisonment for life with fine (3 lakh to 10 lakh). It further perused Section 272 for adulteration of food or drink intended for sale, highlighting the element of intention, and Section 273 for sale of noxious food or drink, hinting towards 'knowledge or reasonable belief'. The Supreme Court held that there were various exhaustive and procedural provisions in the FSSAI which dealt with offences concerning unsafe food and referred to section 89 of the FSSAI act which provides an overriding effect of the provisions of the act over any or all other food related laws."5 The court hence relied on the statutory regulations provided by the FSSAI and allowed the two appeals to set aside the impugned order quashing the offences set under IPC section 272 and 273 and ordered the proceedings to operate as per FSSAI and its relevant provisions.
Impact of the case
The Ram Nath v. State Of Uttar Pradesh case has set a major legal precedent for future legal disputes involving food safety. This judgement by the Hon'ble Supreme Court has reflected upon a growing trend in legal jurisprudence, emphasizing the harmonization of various statutes to achieve a cohesive and effective regulatory framework. The Indian Penal Code carries significant weight and importance in our legal framework, and with respect to the same the court also shed some light in recognizing the importance of the established and specialized regulatory authorities contributing to the evolution of legal jurisprudence in the realm of food related matters.
The impact of this judgement has showcased a more collaborative legal framework to be prevalent in the future. It has bought out a shift towards recognizing and prioritizing specialized statutes and has emphasized the need for a more cohesive and effective regulatory framework. The court has recognized IPC acting as a foundation in this case and supporting and complimenting the regulations established by FSSAI. With the shift in focus and power towards FSSAI in relation to its guidelines and standards, the courts are likely to place significantly more weigh on the technical expertise of FSSAI and all the legal practitioners would need to be well versed with FSSAI in all matters relating to food related matters.
More importantly this judgement has reached out to the consumers out of its legal course as they can expect a more robust and specialized approach to ensure the safety of the food they consume is safe and they have specialized rights for remedy as well. With its effect pertaining to all the food businesses as well, they all would now have to comply and adhere to the more stringent regulations of the FSSAI.
Conclusion
This judgement will be considered as a historic landmark in the food sector reshaping the dynamics of food related legal disputes in India while still setting stone for the future of harmonization of various legal authorities and statutes. By elucidating FSSAI regulations, the Apex Court has recognized the special nature required in food safety and has emphasized the need for a harmonized legal framework. The departure from one law for all has been significantly seen in this judgement where the intricacies of food related matters are recognized and addressed. The impact of this judgement has not only been set till the rooms of a court by setting a historic landmark but has also reached the food business and industries fostering a culture of responsibility and proactive compliance within the food industry. Consumers can be more assured of a robust regulatory framework that prioritizes their safety while the businesses are compelled to elevate their standards to meet the requirements set out by FSSAI. The consequential impact of the case, showcases how a judgement can influence the society as a whole and not only confide itself within the walls of a courtroom. This case is not only a major milestone but has also contributed to a broader societal commitment ensuring integrity and safety of the food supply chain in India.
Ritwik Maini, Intern at S.S. Rana & Co. has assisted in the research of this Article.
Footnotes
Related Posts
FSSAI's Pivotal Amendment to Alcoholic Beverages Regulations
Enhancing Clarity: FSSAI Excludes Nutritional Information from Alcoholic Beverage Labels
Display of Information by E-commerce Food Business Operators- FSSAI
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
