EKNATH SHANKARRAO MUKKAWAR vs STATE OF MAHARASHTRA

The Supreme Court held that the High Court retains the power to enhance sentences under its revisional jurisdiction, as provided in Section 397 read with Section 401 of the Criminal Procedure Code, 1973, despite the existence of an appeal mechanism for the State Government against inadequate sentences. The Court affirmed the conviction of the appellant under Section 16(1)(a)(i) of the Prevention of Food Adulteration Act, 1954, and upheld the High Court's decision to enhance the sentence to six months' simple imprisonment and a fine of Rs. 1000. The judgment clarifies that the High Court's suo motu powers are not abolished by the new Code of Criminal Procedure.