Saumindra Bhattacharya vs State Of Bihar And Anr

The Supreme Court examined the validity of proceedings under the Food Adulteration Act, specifically Sections 11, 12, and 20. The Court held that the Magistrate was not justified in entertaining the complaint against accused No.3 due to non-compliance with the statutory procedure mandated for private complaints. Consequently, the proceedings against accused Nos. 1 and 2 were quashed, while the petition concerning accused No.3 was dismissed, emphasizing the necessity of following prescribed methods for initiating complaints under the Act.