Case Title: TATA Chemicals Limited and others Versus State of Maharashtra
Case No: APPEAL AGAINST ORDER NO. 19 OF 2019
Decided on: 9th May , 2024
Quorum: HON’BLE JUSTICE ANIL L. PANSARE
Facts of the case
It was alleged that TATA Chemicals Limited and other businesses produced and distributed inferior iodized salt. After obtaining samples of the salt from a trader’s location and sending them for analysis, the Food Safety Officer produced a report characterizing the salt as subpar and mislabeled since its sodium chloride content was below recommended levels.
Issues
1.Whether TATA Chemicals’ iodized salt below the standards required by the Food Safety and Standards Act of 2006 when it was produced and sold?
2. Whether the Food Safety Appellate Tribunal’s fines against TATA Chemicals make sense and were they supported by a reliable sample analysis?
3. Whether the obligatory time limit outlined in the Rules of 2011 affect the sample’s quality, and did the sample analysis adhere to it?
4 Whether the report stating that the salt is misbranded and of inferior quality become null due to the non-compliance with procedural requirements?
Legal Provisions
Sections 26 (2) (ii) and 27 (1) of the Food Safety and Standards Act, 2006 (FSSA), which forbid producing and marketing inferior food items, were in issue in this case.
Appellant’s Contentions
TATA Chemicals argued that because the sample analysis was conducted outside of the required time frame outlined in the Rules of 2011, environmental elements such heat, light, and moisture had an impact on the sample’s quality
Respondent’s Contentions
TATA Chemicals was accused by the State of Maharashtra, acting through the Food Safety and Drug Administration, of supplying inferior iodized salt, in violation of the FSSA regulations.
Court Analysis and Judgement
Recently, the Bombay High Court rendered a decision in the litigation pitting the State of Maharashtra against TATA Chemicals Limited and associates. The Food Safety Appellate Tribunal’s (FSAT) ruling against TATA Chemicals Limited concerning the production and distribution of inferior iodized salt was overturned by the court. The Referral Food Laboratory (RFL) was found to have violated the obligatory time limit specified in the Rules of 2011 for the examination of the salt samples, which served as the basis for the High Court’s ruling. Because of this, the RFL report was not in conformity with the statutory provisions, and as a result, the penalty imposed based on that report was not considered to be sustainable. The Food Safety and Standards Authority of India (FSSAI) was also instructed by the court to guarantee procedural compliance in laboratory sample analyses. This ruling highlights the significance of following procedure guidelines and the influence of external influences on food product quality.
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Judgement Analysis Written by – K.Immey Grace