Food Inspector, Ernakulam And Anr vs P.S. Sreenivasa Shenoy

The Supreme Court held that under the Prevention of Food Adulteration Act, 1954, when a report from a Public Analyst is superseded by a certificate from the Director of Central Food Laboratory, it is not necessary to obtain fresh consent to institute prosecution. The Court clarified that the original complaint remains valid despite the new findings, and the trial can proceed without additional sanction under Section 20 of the Act. The appeal by the Food Inspector and the State was allowed, overturning the High Court's directive to wait for fresh consent.