ANDHRA PRADESH GRAIN & SEED MERCHANTS' ASSOCIATION ETC. ETC. versus UNION OF INDIA & ANR.

ANDHRA PRADESH GRAIN & SEED MERCHANTS' ASSOCIATION ETC. ETC. versus UNION OF INDIA & ANR.

The Supreme Court upheld the constitutional validity of Sections 7, 10, and 19 of the Prevention of Food Adulteration Act, 1954. It held that the Act's imposition of absolute liability is justified by the public interest in controlling food adulteration and that the restrictions are reasonable. The exclusion of mens...

Source-derived case information.

Parties
Petitioner: Andhra Pradesh Grain & Seed Merchants' Association Etc. Etc.; Respondent: Union of India; Respondent: Another Respondent (No. 2)
Jurisdiction
India
Judgment Date
31 March 1970
Procedural Posture
Writ Petition Under Article 32 of the Constitution of India / Final Judgment
Outcome
Petitions dismissed
Legal Topics
Reasonableness of Restrictions Under Article 19(1)(g), Article 14 Equality, Article 20(3) Right Against Self Incrimination, Constitutional Validity of Statutes, Mens Rea in Statutory Offences, Public Health Regulation
Constitutional Law Criminal Law Food Safety Law Reasonableness of Restrictions Under Article 19(1)(g) Article 14 Equality Article 20(3) Right Against Self Incrimination Constitutional Validity of Statutes Mens Rea in Statutory Offences +1 more

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Legal principles 3 Authorities cited 6 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

Andhra Pradesh Grain & Seed Merchants' Association Etc. Etc.

Petitioner

Union of India

Respondent

Another Respondent (No. 2)

Respondent

Procedural Posture

Writ Petition Under Article 32 of the Constitution of India / Final Judgment

Legal Issues

  1. 1 Whether Sections 7, 10, and 19 of the Prevention of Food Adulteration Act, 1954 violate Articles 14, 19(1)(g), and 20(3) of the Constitution of India
  2. 2 Whether the Act unreasonably restricts traders and imposes penalties without regard to mens rea
  3. 3 Whether conclusive evidentiary value of laboratory certificates violates Article 20(3)

Ratio Decidendi

The Supreme Court upheld the constitutional validity of Sections 7, 10, and 19 of the Prevention of Food Adulteration Act, 1954. It held that the Act's imposition of absolute liability is justified by the public interest in controlling food adulteration and that the restrictions are reasonable. The exclusion of mens rea as an ingredient of the offence, the proportionality of penalties, and the conclusiveness of laboratory certificates do not violate Articles 14, 19(1)(g), or 20(3) of the Constitution.

Court Disposition

Petitions dismissed

Orders

  • The petitions are dismissed with costs. One hearing fee awarded.