DELHI CLOTH & GENERAL MILLS CO. LTD. vs STATE OF M.P. AND OTHERS

The Supreme Court interpreted Section 20A of the Prevention of Food Adulteration Act, 1954, holding that a manufacturer can be summoned during the trial of a dealer for selling adulterated food. The Court clarified that the Magistrate has the authority to proceed against the manufacturer if evidence suggests their involvement in the offence, despite the dealer being the immediate accused. The appeal was dismissed, affirming the lower courts' decisions to allow the prosecution against the manufacturer.