MANIPUR ADMINISTRATION vs M. NILA CHANDRA SINGH

The Supreme Court held that under Clause 2(a) of the Manipur Foodgrains Dealers Licensing Order, 1958, a person must be shown to carry on a business of purchase, sale, or storage for sale of specified commodities to be classified as a dealer. The Court clarified that Clause 3(2) raises a presumption regarding the storage of 100 mds. or more of goods, but this does not automatically imply the individual is a dealer under Clause 3(1) without evidence of business continuity. The appeal was allowed, overturning the Judicial Commissioner's ruling and reinstating the conviction under Section 7 of the Essential Commodities Act, 1955.