T. BARAI vs HENRY AH HOE AND ANOTHER

The Supreme Court ruled that the Central Amendment Act of 1976, which reduced the punishment for offences under Section 16(1)(a) of the Prevention of Food Adulteration Act, 1954, impliedly repealed the West Bengal Amendment Act of 1973 that had enhanced the punishment. The Court held that all pending trials for offences under the West Bengal Amendment Act would cease to be governed by it and would instead follow the provisions of the Central Act as amended. The decision clarified the applicability of Section 6 of the General Clauses Act regarding the transition of laws and the preservation of liabilities incurred under the repealed Act.