Sunday, 7 April 2013

Duty of prosecution to inform accused to get sample analysed by the CFL in case of food adulteration Act


As the object of the PFA Act is to prevent adulteration of food, 
this Act embodies very stringent provisions for penalty by making minimum 
imprisonment of three months mandatory. Since the scheme of this Act 
shows that the conviction of the accused, eventually, rests on the Public 
Analyst's report and when the legislature, in its wisdom, has used the word Criminal Petition No. 654 of 2004 
'inform' under Section 13(2), the provisions of Section 13(2) have to be strictly 
construed. Construed thus, it becomes clear that it is imperative for the 
prosecution to prove that the accused knew that he had a right to get 
sample analysed by the CFL and that this knowledge has been derived by 
the accused from the notice issued under Section 13(2). If the prosecution 
fails to prove such knowledge on the part of the accused, it will but be 
necessary for the Court to treat that prejudice has been caused to the 
accused by non-compliance of this mandatory requirement.

IN THE GAUHATI HIGH COURT
THE HIGH COURT OF ASSAM; NAGALAND; MEGHALAYA; MANIPUR; 
MIZORAM; TRIPURA AND ARUNACHAL PRADESH
CRIMINAL REVISION NO. 654 OF 2004
1) Shri Sukumar Roy

Versus
THE STATE OF ASSAM.



By the judgment and order, dated 30.09.2004, passed, in criminal 
Appeal No. 10(1)/2004, by the learned Session Judge, Cachar, Silchar, the 
appeal has been dismissed and the judgment and order, dated 30.01.2004, 
passed, in CR 1614/2000, by the learned Chief Judicial Magistrate, Cachar, 
Silchar, convicting the two accused-petitioners, under Section 7 read with 
Section 16 of the Prevention of Food Adulteration Act (hereinafter referred to Criminal Petition No. 654 of 2004 Page 2 of 10
Page No. 2 
as ‘the PFA Act’) and sentencing each one of them to undergo rigorous 
imprisonment for 6 months and pay fine of Rs. 1,000/ and, in default of 
payment of fine, suffer simple imprisonment for 30 days, stands upheld. 
2. The case of the prosecution may, in brief, be described thus: On 
26.05.2000, Senior Food Inspector (PW1) visited the shop, belonging to 
accused-petitioner, namely, Sukumar Chandra Roy, who was not present at 
his shop and, upon serving a notice, in Form-VI, on accused-petitioner, 
namely, Sudip Roy, purchased 600 grams of beson and 600 grams of Moong 
daal (whole) for sending the same to the Public Analyst for analysis. The 
Public Analyst submitted his report that the samples of beson and moongdal
(whole), sent to him, for analysis, were found adulterated. 
3. In the case at hand, we are concerned with the conviction of 
the accused-petitioners for sale of adulterated moong daal (whole) and we, 
therefore, keep ourselves confined to the accused-petitioners’ trial for
allegedly selling the adulterated moongdal (whole).
4. Based on the report of the Public Analyst, Assam, that the 
sample of moong daal (whole), received by him, was found adulterated 
inasmuch as the same did not conform to the standard, the Food Inspector 
applied to the Local (Health) Authority for sanction and, on receiving the 
requisite sanction, submitted a complain, in writing, to the Chief Judicial 
Magistrate, Cachar, Silchar, seeking prosecution of the accused-petitioners 
under Section 7 read with Section 16 of the PFA Act. Notices, as required by 
Section 13(2) of the PFA Act, were sent to both the accused-petitioners
informing them that if they so chose, they could get the sample analyzed by 
Central Food Laboratory. The accused-petitioners did not, however, apply 
for sending one of the samples of the said food article, kept in the custody of 
the Local (Health) Authority, to the Central Food Laboratory for analysis. Criminal Petition No. 654 of 2004 Page 3 of 10
Page No. 3 
5. At the trial, when a charge under Section 7 read with Section 16 
of the PFA Act were framed against the present accused-petitioners, both of 
them pleaded not guilty thereto. 
6. In support of their case, prosecution examined the Food 
Inspector as the only witness. The two accused were, then, examined under 
Section 313 CrP.C. and, in their examinations aforementioned, while the 
accused-petitioner No.1, namely, Sukumar Roy, responded by saying that he 
had received the report of public analyst, which is claimed to have been 
sent to him in terms of Section 13(2) of the PFA Act, the accused-petitioner 
No.2, namely, Sujit Roy, responded by saying that he did not remember if he 
had received the said report of the Public Analyst. The defence, too, 
adduced evidence by examining both the accused-petitioners.
7. Having, however, found both the accused-petitioners guilty of
the offence charged with, the learned trial Court convicted them 
accordingly and passed sentence against them as mentioned above. Since 
the appeal, which the accused-petitioners had preferred, stands dismissed, 
the accused-petitioners are, now, before this court challenging, with the 
help of the present revision, finding of guilt reached against them and the 
consequential sentences, which have been passed against them. 
8. I have heard Mr. J. Roy, learned Counsel for accused-petitioners,
and Mr. K. Munir, learned Additional Public Prosecutor, Assam. 
9. While considering present revision, it is pertinent to note that the 
Food Inspector claims that in terms of the instructions of the Local (Health)
Authority, he sent, in terms of the requirements of Sections 13(2), the report of 
the Public Analyst to both the accused-petitioners by Peon Book. Though the 
Food Inspector has proved the signatures of the two accused-petitioners, 
there is no evidence on the record that he (Food Inspector) was acquainted
with the hand-writing and/or the signature of either of the two accusedpetitioners nor is there any evidence on record indicating that the signatures Criminal Petition No. 654 of 2004 Page 4 of 10
Page No. 4 
aforementioned had been put, on the said Peon Book, by the two accusedpetitioners in the presence of PW1 (Food Inspector). Far from this, the Food 
Inspector, during his cross-examination, recalled the name of the said Peon 
as Phani Bhusan Das; but the said Phani Bhusan Das was never examined as
a witness. 
10. Strictly speaking, therefore, the signatures of the two accusedpetitioners, in the Peon Book, had not been proved and the fact as to 
whether the two accused-petitioners had or had not received the Public 
Analyst’s report, thus, remained unproved facts.
11. In the circumstances mentioned above, one is required to 
consider the evidence of the accused-petitioners and what transpires from 
their evidence is that they denied that they had received the notices, which 
were claimed to have been sent to them in terms of the requirements of 
Section 13(2). The evidence, so given, remained unshaken in the crossexamination.
12. Situated, thus, it is clear that the prosecution had failed to prove
that any notice, as has been provided by Section 13(2), was sent to, and 
received by, the two accused-petitioners. 
13. The question, which, now, arises for consideration is: When a 
notice, in terms of the mandate of Section 13(2), is not received by the 
vendor concerned, what would be the consequence ?
14. While considering the question, posed above, it is of paramount 
importance to note that in State of Orissa v. Gauranga Sahu, reported in 2003 
Cr LJ 3077 (SC), the question raised was: whether, on finding that the 
mandate of sub-section (2) of Section 13 of the PFA Act had been complied 
with, the High Court ought to have acquitted the accused holding that a 
statutory valuable right, available to the accused, had been taken away. 
Dealing with this aspect of the matter, the Supreme Court observed and held 
as follows: Criminal Petition No. 654 of 2004 Page 5 of 10
Page No. 5 
"4. It is argued on behalf of the accused that mere dispatch of the 
report is not enough; and that the prosecution is further obliged to 
proved that the letter so dispatched had reached the addressee, i. e. 
the accused. We agree with this submission, as we believe that 
forwarding a copy of the report is not only a ritual, but also a statutory 
requirement to be mandatorily observed in all the cases. Dispatch of 
such a report is intended in inform the accused of his valuable right to 
get the other sample analysed from the Central Food Laboratory. " 
(Emphasis is added)
15. From what have been held by the Supreme Court in Gauranga 
Sahu (supra), it becomes transparent that the prosecution, besides proving 
that a copy of the public analyst’s report had been forwarded to the 
accused in terms of Section 13(2) of the PFA Act, must also prove that the 
notice/letter, dispatched in terms of Section 13 (2), had reached the 
addressee i. e. the accused, for, this obligation is not a mere ritual, but a 
statutory mandate, which must be observed in all cases. 
16. The law, so clearly laid down by the Supreme Court, in Gauranga 
Sahu (supra), leaves no room for doubt that compliance of Section 13 (2) will 
not be treated complete unless the prosecution discharges its additional 
obligation of proving, by adducing cogent evidence, that the notice, issued 
under Section 13(2), has been served upon, and/or received by, the 
accused. 
17. The object, as the decision in Gauranga Sahu (supra) reflects, is 
to 'inform' the accused about his valuable right to get the sample analysed 
by the Central Food Laboratory. Whether in the facts of a given case, the 
notice can be treated to have been served on an accused or not will, 
however, be a question of fact, which has to be determined on the basis of 
the facts of the given case. In the set of facts proved in Gauranga SahuCriminal Petition No. 654 of 2004 Page 6 of 10
Page No. 6 
(supra), the Court held that the letter, issued in terms of Section 13 (2), had 
been proved to have been received by the accused. 
18. That Section 13 (2) is mandatory, in nature, has been accepted 
by this Court in its decision, namely, Shyamal Nag v. State of Assam, reported 
in 2004 (1) GLT 667, wherein the Court has observed, on taking note of the 
decision in Gauranga Sahu (supra), thus: ". . . . . . . . It can be safely said the 
Section 13 (2) is mandatory in nature and it confers valuable right on the 
accused, denial of which would constitute prejudice to the accused entitling 
him to acquittal." (Emphasis is added)
19. The question, which, now, arises, is: whether non-compliance of 
Section 13 (2) will per se vitiate the trial or the accused is required to prove 
that prejudice has been caused to him, because of non-service of the public 
analyst’s report. While dealing with this aspect of the matter, it is of prime 
importance to note that to receive ‘fair trial’ is the constitutional right of 
every accused and the State carries the corresponding duty, in terms of 
Article 21 of the Constitution, to provide ‘fair trial’ to the accused. The right to 
have ‘fair trial’ by an accused means that the trial has to be fair at its every 
stage. 
20. When the Supreme Court has held, in Gauranga Sahu (supra), 
that the forwarding of a letter/notice alongwith the report to the accused, in 
terms of Section 13 (2), constitutes a valuable right of the accused to get the 
sample analysed by the Central Food Laboratory, it logically follows that the 
compliance of Section 13 (2) becomes mandatory, for, this compliance 
becomes a condition precedent for a ‘fair trial’. If it is not followed, then, the 
provisions of Section 13 (2) being mandatory, the non-compliance thereof 
will per se vitiate the trial. 
21. It was sought to be raised, on behalf of the prosecution, that 
even if there is no direct or cogent evidence to prove that the notice, under 
Section 13(2), had been received by the accused, the accused can very Criminal Petition No. 654 of 2004 Page 7 of 10
Page No. 7 
well, while appearing in the Court, in pursuance of the summons issued for 
trial, apply for sending one part of the sample to the Central Food Laboratory 
(hereinafter as 'the CFL' ). While considering this facet of the prosecution's 
argument, it is imperative to note that the object of Section 13 (2), as the 
decision in Gauranga Sahu (supra), shows and as has been pointed out 
herein above, is that the accused be ‘informed’ of his right to get the sample 
analysed from the CFL. 
22. In view of the fact that the object of giving of a notice, under 
Section 13 (2), is really to 'inform' the accused of his valuable right to get the 
sample analysed from the CFL, it is not enough for the prosecution to say, in 
the light of the decision in Gauranga Sahu (supra), that the accused ought to 
have known the law that he has the right to get the sample analysed from 
the CFL. The obligation of the prosecution is really to 'inform' the accused of 
his right to get the sample analysed from the CFL. If the accused in not 
informed that he has a right to send the sample for analysis, the mere fact 
that the report had been received by the accused will be of no material 
consequence. 
23. Considered thus, the object, under Section 13(2), is not to merely 
ensure that the accused gets, if he so opts, analysed a part of the sample 
from the CFL, but the purpose is also to 'inform' the accused that he has such 
a right vested in him. Giving of adequate 'information' is, thus, an essential 
ingredient of Section 13 (2) and this cannot be said to have been achieved 
unless cogent evidence is adduced to show that such an 'information' had, 
indeed, been made available to the accused. 
24. In a prosecution under the PFA Act, it is essentially the report of 
the Public Analyst, which forms the basis for conviction of the accused; 
hence, it is quite logical that the legislature, in their wisdom, deemed it 
mandatory for the State to not only serve a copy of the Public Analyst's 
report on the accused, but also to ‘inform’ the accused of his right to get the Criminal Petition No. 654 of 2004 Page 8 of 10
Page No. 8 
sample analysed from the CFL. It further logically follows that if merely a copy 
of the report of the Public Analyst is served on the accused, this, in itself, will 
not constitute compliance of Section 13(2). Far from this, the prosecution has 
also the obligation to prove, convincingly and beyond doubt, that the 
accused had been ‘informed’ that he had a right to get analysed the 
sample by the CFL. If this ‘information’ is not given to the accused, serving of 
the report of the Public Analyst on the accused, will be a mere ritual and will 
not satisfy the rigour of Section 13 (2). 
25. A microscopic reading of the provisions of Section 13 (2) shows, if 
I may reiterate, that the object, behind Section 13(2), is not merely to make a 
report of the Public Analyst reach the accused, but also to 'inform' him that 
he has a right to get the sample examined by the CFL. The underlying 
emphasis, in Section 13(2), is on the word 'information'. The dictionary 
meaning of the word 'information' is the knowledge communicated or 
received concerning a particular fact or circumstance, that is to say, let the 
accused know that he has a right to get the sample analysed by the CFL. 
Thus, Section 13(2) is an exception to the general philosophy that ignorance 
of law is no excuse and it can be no argument that irrespective of the fact 
whether the accused had received the notice under Section 13 (2) or not, he 
could have, on his appearance in the Court, prayed for sending a part of the 
sample to the CFL for analysis. 
26. In Ratanlal Agarwalla vs. State of Assam, (1993) 1 GLR 286, the 
Full Bench of our High Court construed that the word 'forward', used in 
Section 13(2), indicates that the obligation of the prosecution is merely to 
send notice to the place or destination and does not mean ‘serve’ or 
‘deliver’. Having so construed, the Full Bench concluded that Section 13(2) is 
‘directory’ and its non-compliance would not per se vitiate the trial. 
27. In view, however, of the fact that the Supreme Court has, now, 
held, in Gauranga Sahu (supra), that the prosecution's burden is not Criminal Petition No. 654 of 2004 Page 9 of 10
Page No. 9 
discharged merely by sending the notice under Section 13 (2), but it must 
also ensure that the notice is received by the accused, for, the purpose of 
dispatch of the report is to ‘inform’ the accused of his valuable right to get 
the sample analysed from the CFL, there can be no escape from the 
conclusion that Section 13(2) is mandatory and non-compliance thereof per 
se vitiates the trial. 
28. Since the object of Section 13(2) is really to 'inform' the accused 
that he has the option to get the sample analysed by the CFL, it is clear that 
for achievement of this object, the condition precedent is that the notice, 
under Section 13(2), be received by, and/or served upon, the addressee. 
Hence, if the report of the public Analyst is merely sent with a forwarding 
letter and even if the same is received by the addressee, the provisions of 
Section 13(2) will not be complied with, for, mere receipt of the report by the 
addressee does not fulfill the object of Section 13(2) until the ‘information’ is 
also given to the addressee that he has the option to get the sample 
analysed by the CFL. 
29. Because of the fact that the object of Section 13(2) is to ‘inform’
the accused of his right to get the sample analysed by the CFL, its noncompliance will per se vitiate the trial and, in such a case, prejudice will be 
implicit in such non-compliance, for, the accused would not be knowing that 
he has the right to get sample analysed and the report, which the Public 
Analyst has given, can be superseded by the result, which the analysis from 
by CFL will render. The lack of 'information', on the part of the accused, is, in 
itself, a cause of prejudice and the same is sufficient to vitiate the trial. 
30. As the object of the PFA Act is to prevent adulteration of food, 
this Act embodies very stringent provisions for penalty by making minimum 
imprisonment of three months mandatory. Since the scheme of this Act 
shows that the conviction of the accused, eventually, rests on the Public 
Analyst's report and when the legislature, in its wisdom, has used the word Criminal Petition No. 654 of 2004 Page 10 of 
10
Page No. 10 
'inform' under Section 13(2), the provisions of Section 13(2) have to be strictly 
construed. Construed thus, it becomes clear that it is imperative for the 
prosecution to prove that the accused knew that he had a right to get 
sample analysed by the CFL and that this knowledge has been derived by 
the accused from the notice issued under Section 13(2). If the prosecution 
fails to prove such knowledge on the part of the accused, it will but be 
necessary for the Court to treat that prejudice has been caused to the 
accused by non-compliance of this mandatory requirement.
31. Because of what have been discussed and pointed out above, 
the two accused-petitioners could not have been convicted of the charge 
framed against them.
32. In the result and for the foregoing reasons, this revision succeeds, 
the impugned judgments and orders are hereby set aside. Both the 
accused-petitioners held not guilty of the charge framed against them and 
they are acquitted of the same.
33. Send back the LCR.
JUDGE
Paul

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