VIJAY KUMAR vs STATE OF PUNJAB

The Supreme Court upheld the conviction of the appellant under Section 16(1)(a)(i) of the Prevention of Food Adulteration Act, 1954, for selling 'Elachi Dana' that was found to be insect-infested (9.7%) and contained less than the required volatile oil content (0.5% instead of 1%). The Court clarified that the applicable rules mandated a minimum of 1% volatile oil in 'Badi Elachi', and the appellant's argument regarding the absence of standards at the time of sampling was rejected. The Court also found that the sample could not have become infested within the 12 days before analysis, affirming the conviction and sentence imposed by the lower courts.