PRAVIN CHANDRA MODY vs STATE OF ANDHRA PRADESH

The Supreme Court held that a report under Section 11 of the Essential Commodities Act, 1955 does not constitute a charge-sheet under Section 173 of the Code of Criminal Procedure, 1898. The Court clarified that cases under clauses (a) and (c) of Section 190(1) are triable under Section 252, while those under clause (b) are triable under Section 251-A. Since the police report was made under Section 173, the trial was rightly conducted under Section 251-A, affirming the lower courts' decisions.