Citation Codes

Equivalent Citations

citation codes

Case Number

Criminal Revn. No. 145 of 1966, from order of S.J; Puri

Judges

G.K Misra, J.

Acts

S. 16(1)(a) of the Prevention of Pood Adulteration Act (Act No. 37 of 1954) (hereinafter referred to as the Act)
Prevention of Pood Adulteration Rules, 1955 (hereinafter referred
PREVENTION OF FOOD ADULTERATION ACT 1954
sample.12. Rule 7 prescribed duties of Public Analyst:(1)
sections 272 to 276 of the Indian Penal Code (45
sub-rule (2) of Rule 7 of the Rules.
provisions of Rules 18 and 7(1).
S. 114 of the Evidence Act
Public Analyst.6. Rule 18
S. 11, sub-section (1)(c)(ii)
provisions of Rule 20.
conviction.23. Rule 5
analysis.10. Rule 20
him.8. Rule 19
be.4. Rule 16
Rule 7(3).15.
sub-rule (2)
sub-rule (1)
Rule 7(1).

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Smart Summary

Structured Summary of the Opinion

Factual and Procedural Background

(Summary strictly based on the provided opinion.)

The petitioner was convicted under S. 16(1)(a) of the Prevention of Food Adulteration Act, 1954 and sentenced to pay a fine of Rs. 250, in default to undergo rigorous imprisonment for one month. The prosecution case was that the petitioner was carrying adulterated milk for sale in Puri town on 15-6-1963. The defence maintained that the milk was not being taken for sale and that there was no adulteration. The learned Courts below concurrently found that the milk was adulterated.

On revision, the defence (represented by Mr. Harichandan) advanced two principal contentions: (1) that mandatory Rules 7 and 18 of the Prevention of Food Adulteration Rules, 1955 were not complied with (specifically, that a specimen impression of the seal and a copy of the memorandum were not separately sent to the Public Analyst and the Public Analyst did not compare the seals with a separately received specimen impression), and (2) that there was an inordinate delay (about five and a half months) between seizure (15-6-1963) and the launch of prosecution (5-12-1963), during which the milk decomposed, depriving the petitioner of a real opportunity to obtain a superseding certificate from the Director of the Central Food Laboratory under S. 13(2).

Legal Issues Presented

Whether non-production of direct evidence that a specimen impression of the seal and a copy of the memorandum were separately sent to the Public Analyst (as required by Rules 7 and 18) invalidates the Public Analyst's report and, consequently, the conviction based on that report.
Whether the delay between seizure and prosecution (approximately five and a half months) resulting in alleged decomposition of the milk deprived the petitioner of the effective right under S. 13(2) to have a part of the sample sent to the Director of the Central Food Laboratory for a superseding certificate, thereby prejudicing the accused and vitiating the conviction.

Arguments of the Parties

Petitioner's Arguments

Rule 18 and Rule 7(1) were not complied with: there was no proof that a copy of the memorandum and a specimen impression of the seal used to seal the packet were separately sent to the Public Analyst and that the Analyst made the comparison as required; therefore the Public Analyst's report is vitiated and conviction based solely on that report is illegal.
There was an unexplained delay of about five and a half months between seizure and prosecution. During that interval the milk would have decomposed, altering constituent measurements (fat and solids-not-fat), so the Public Analyst's report does not reliably indicate adulteration. Further, the delay effectively deprived the petitioner of a real opportunity to obtain a superseding certificate from the Director of the Central Food Laboratory under S.13(2).

Prosecution / Court-Noted Position

It was not disputed that the Food Inspector (P.W.2) complied with S. 10 and S. 11: one part was delivered to the person, another sent to the Public Analyst, and a third retained. Formalin was added to the milk as preservative in compliance with Rule 20.
No positive evidence was produced to show that the sample had decomposed despite the addition of the prescribed preservative. The petitioner did not summon and cross-examine the Public Analyst to establish decomposition or to challenge the analysis process or results.

Table of Precedents Cited

(Each entry below reflects only the role and statement of the precedent as described in the provided opinion.)

Precedent	Rule or Principle Cited For	Application by the Court
A.I.R. 1951 Nag. 191 — Dattappa Mahadappa v. Secretary, Municipal Committee Buldana	Authority cited (with other cases) for the proposition that prosecution must establish that a specimen impression of the seal was sent separately and that the Public Analyst compared the seal with the separately received specimen impression as required by Rule 7(1).	The Court recognized the proposition as correct in its bald form but observed these earlier decisions did not examine whether, in the absence of direct evidence, the Court could infer compliance from the Public Analyst's Form No. III report.
A.I.R. 1964 Guj. 136	Cited among authorities for the proposition about proving the sending and comparison of specimen impressions and compliance with Rules 7 and 18.	The Court treated it as part of the group of authorities stating the prosecution must establish sending and comparison, but differentiated the present case on whether the Public Analyst's certificate in Form III itself can be proof of compliance.
State v. Shantaben (31 Cut LT 1008 : AIR 1966 Ori 188)	Cited for the same proposition: requirement that prosecution establish sending and comparison of specimen impressions under Rule 7(1) and Rule 18.	The Court acknowledged the proposition but considered whether the Form III report can be treated as evidence of compliance in the absence of positive proof by the prosecution.
AIR 1928 Mad 77 — Sona Chalam Piliai v. Kumaravalu Chettiar	Authority for the proposition that courts may presume that judicial and official acts have been regularly performed (invoking the presumption under S. 114 of the Evidence Act).	The Court relied on this principle to support a presumption that the Public Analyst had performed the mandated comparisons and procedures, in the absence of contrary evidence.
32 Cut LT 18 : AIR 1966 Ori 81 — State v. Uma Charan	Cited as taking the same view (that the Public Analyst's report may support an inference of compliance with Rules 7 and 18 in the absence of contrary evidence).	The Court accepted that decision as laying down the correct law and applied the same reasoning in concluding that a Form III report can be evidence of compliance absent opposite proof.
AIR 1967 SC 970 — Municipal Corporation of Delhi v. Ghisa Ram	Cited for the principle that prosecution must proceed with reasonable promptness so that the accused's right under S.13(2) (to have part of the sample sent to the Director of the Central Food Laboratory) is not rendered illusory; deliberate conduct of prosecution causing denial of that right may prejudice the accused to such an extent that conviction should not be upheld on the Public Analyst's report alone.	The Court invoked these observations to examine whether the delay in launching prosecution here (about 5½ months) prejudiced the accused; concluding that, in the circumstances and having regard to the likelihood of decomposition over that period, the delay did affect the accused's right and required setting aside the conviction.

Court's Reasoning and Analysis

(Presented as the court developed it in the opinion, without adding outside inferences.)

The court first set out the statutory and regulatory framework relevant to sampling and analysis:
- S.10(1)(a)(i) — power of Food/Pood Inspector to take samples (the Pood Inspector purchased the milk sample).
- S.11(1)(c) — the Food Inspector must (i) deliver one part of the sample to the person from whom taken; (ii) send another part for analysis to the Public Analyst; and (iii) retain a third part for production or for analysis by the Director of the Central Food Laboratory under S.13(2).
- Rules 16–20 — packing, sending containers, requirement at Rule 18 that a copy of the memorandum and a specimen impression of the seal be sent separately to the Public Analyst, and Rule 20 prescribing formalin as preservative for milk (two drops per ounce).
- Rule 7(1) — on receipt of a package the Public Analyst shall compare the seal on the container and outer cover with the specimen impression received separately and note the condition of the seals; Rule 7(3) — the Public Analyst supplies a report in Form III after analysis.
- S.13 — the Public Analyst must deliver a report; after institution of prosecution the accused may apply for sending the retained part to the Director, whose certificate would supersede the Public Analyst's report.
First contention (non-compliance with Rules 7 and 18):
- The prosecution relied on the Public Analyst's report in Form III, which expressly certifies that the sample was "properly sealed and fastened" and that the Public Analyst "found the seal intact and unbroken."
- The Court observed that earlier decisions stated the prosecution must specifically establish that a specimen impression was separately sent and that a comparison was made. However, those decisions did not consider whether a Form III report itself — which certifies the condition of the seals — permits an inference of compliance where there is no direct evidence to the contrary.
- The Court held that the report in Form III is preceded by ostensible acts (the prescribed comparison and the analysis) and that, where there is no contrary evidence, the Form III report itself constitutes evidence that Rules 7(1) and 18 were complied with.
- Further, the court invoked the presumption under S.114 of the Evidence Act that official acts are regularly performed; from the Public Analyst's certificate the court may presume compliance with mandatory procedures in the absence of evidence to the contrary.
- Accordingly, the first contention was rejected for lack of substance.
Second contention (delay and decomposition; denial of effective right under S.13(2)):
- Chronology: samples taken 15-6-1963; Public Analyst's report dated 29-8-1963; prosecution launched 5-12-1963 — roughly 5½ months after seizure.
- The Public Analyst's measured values: fat content 1.8% and milk solids other than fat 7.9% (below the standards cited from Appendix B, viz., cow milk standards such as minimum fat and solids-not-fat percentages as applicable to the region).
- The petitioner argued that decomposition (allegedly occurring before analysis and/or by the time of prosecution) would change constituent measures and render the analysis unreliable. The Court found no materials or authoritative evidence to support the contention that the sample had decomposed despite the addition of the prescribed preservative (formalin), and noted that the petitioner could have summoned the Public Analyst for cross-examination to prove decomposition but did not do so. This limb was rejected.
- However, the Court accepted that the delay between the Public Analyst's report (29-8-1963) and the institution of prosecution (5-12-1963) could have practical consequences. Citing Municipal Corporation of Delhi v. Ghisa Ram, the Court noted the principle that prosecution must be launched with reasonable promptness so that the statutory right of the accused to seek a superseding certificate from the Director of the Central Food Laboratory is not rendered illusory. If that right is effectively denied by prosecutorial delay, the accused may be so prejudiced that conviction on the basis of the Public Analyst's report should not be upheld.
- Applying that reasoning and having regard to the nature of milk and the period of delay (the court expressed the view that milk would get decomposed after a period of about five and a half months), the Court concluded that the delay affected the petitioner's right to challenge the Public Analyst's report through the Director's certificate and thus prejudiced the defence.
- On that basis the Court found that the petitioner was entitled to the benefit of the doubt arising from the prosecutorial delay.

Holding and Implications

Holding (core ruling): Revision allowed; the order of conviction and sentence was set aside.

Direct consequences for the parties:

The petitioner's conviction under S.16(1)(a) of the Prevention of Food Adulteration Act and the sentence (fine Rs.250 in default one month R.I.) were quashed by the revisional court.

Broader implications and note on precedent:

The Court reaffirmed that a Public Analyst's Form III report, which certifies that the sample was properly sealed and that the seal was intact, can be treated as evidence of compliance with the procedural requirements of Rules 7(1) and 18 in the absence of direct contrary evidence, relying on the presumption under S.114 of the Evidence Act. This clarification was explicitly applied to reject the first contention in the present case.
At the same time, the Court applied the principle from Municipal Corporation of Delhi v. Ghisa Ram that unreasonable prosecutorial delay which effectively defeats the accused's statutory right to obtain a superseding certificate from the Director of the Central Food Laboratory may prejudice the accused and justify setting aside a conviction. On the facts before it (delay of about 5½ months and the particular susceptibilities of milk to decomposition), the Court found such prejudice and allowed revision.
The opinion addresses the specific facts of this case rather than announcing a novel general rule; the decision thus resolves the appeal by applying existing principles (the evidentiary role of Form III reports and the requirement of reasonable promptness in prosecution to preserve the accused's statutory rights). No claim of establishing an entirely new precedent is made in the text.

Disposition as recorded in the opinion: "Revision allowed." (Final line of the judgment.)

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Satrughna Behera v. Puri Municipality Opposite Party.

1. The petitioner has been convicted under S. 16(1)(a) of the Prevention of Pood Adulteration Act (Act No. 37 of 1954) (hereinafter referred to as the Act) and sentenced to pay a fine of Rs. 250 in default to undergo Rigorous Imprisonment for one month. Prosecution case is that the petitioner was carrying adulterated milk for sale in Puri town on 15-6-63. The defence was that the milk was not being taken for sale and there was no adulteration. The learned Courts below concurrently found that the milk was adulterated. Mr. Harichandan advanced two contentions:—

(1) Prosecution infringed Rr. 7 and 18 of the Prevention of Pood Adulteration Rules, 1955 (hereinafter referred to as the Rules) inasmuch as there is no proof that a specimen impression of the seal the packet was sent to the public Analyst separately and the Public Analyst compared the seal on the container and the outer cover with the specimen impression received separately. Infringement of these mandatory rules vitiated the report of the Public Analyst. The conviction based on such a report only is illegal.

(2) The prosecution was launched about five and half months after the detection when the milk had decomposed. The delay in prosecution resulted in the petitioner being deprived of the opportunity of asking the Court for sending a part of the sample to the Director of the Central Pood Laboratory for a certificate which would have superseded the report of the Public Analyst.

2. Both the contentions require careful attention.

3. To appreciate the aforesaid contentions, the relevant provisions of the Act and the Rules may be noticed. Under S. 10(1)(a)(i) of the Act, a Pood Inspector shall have power to take samples of any article of food from any person selling such article. In this case, the Pood Inspector (P.W 2) purchased the milk taken as sample. Section 11 prescribed the procedure to be followed by Pood Inspectors. Under S. 11, sub-s. (1), cl. (c), the Food Inspector shall do the following things:—

(i) deliver one of the parts to the person from whom the sample has been taken;

(ii) send another part for analysis to the Public Analyst; and

(iii) retain the third part for production in case any legal proceedings are taken or for analysis by the Director of the Central Food Laboratory under sub-s. (2) of S. 13, as the case may be.

4. Rule 16 lays down the manner of packing and sealing the samples Rule 17 prescribes how the containers of samples are to be sent to the Public Analyst.

5. The containers of samples for analysis shall be sent to the Public Analyst by registered post or railway parcel or air freight, or by hand in a sealed packet, enclosed together with a memorandum in Form VII in an outer cover addressed to the Public Analyst.

6. Rule 18 says that—

7. a copy of the memorandum and a specimen impression of the seal used to seal the packet shall be sent to the Public Analyst separately by registered post or delivered to him or to any person authorised by him.

8. Rule 19 deals with addition of preservatives to samples.

9. Any person taking a simple of any food for the purpose of analysis under the Act may add a preservative as may be prescribed from time to time to the sample for the purpose of maintaining it in a condition suitable for analysis.

10. Rule 20 speaks of preservative in respect of milk, cream and gur—

11. The preservative used in the case of samples of any milk including toned, separated and skimmed milk, cream-ice-cream, mixed ice-cream, ice candy, dahi and gur in liquid or semi-liquid form shall be the liquid commonly known as “formalin,” that is to say, a liquid containing about 40 per cent of formaldehyde in aqueous solution, in the proportion of two drops for one ounce of the sample.

12. Rule 7 prescribed duties of Public Analyst:

(1) On receipt of a package containing a sample for analysis from Pood Inspector or any other person, the Public Analyst or an officer authorised by him shall compare the seal on the container and the outer cover with specimen impression received separately and shall note the conditions of the seal thereon.

(3) After the analysis has been completed he shall forthwith supply to the person concerned a report in Form in of the result of such analysis.

13. Section 13 runs thus:—

“13. Report of public analyst — (1) the Public Analyst shall deliver, in such form as may be prescribed, a, report to the food inspector of the result of the analysis of any article of food submitted to him for analysis.

(2) After the institution of a prosecution under this Act the accused vendor or the complainant may, on payment of the prescribed fee make an application to the Court for sending the part of sample mentioned in sub-cl. (i) or sub-cl. (iii) of cl. (c) of sub-s. (1) of S. 2 to the Director of the Central Food Laboratory for a certificate; and on receipt of the application the Court shall first ascertain that the mark and seal or fastening as provided in cl. (b) of sub-S. (1) of S. 2 are intact and may then despatch the part of the sample under its own foal to the Director of the Central Food Laboratory who shall thereupon send a certificate to the Court in the prescribed form within one month from the date of receipt of the sample specifying the result of his analysis.

(3) The certificate issued by the Director of the Central Food Laboratory under sub-S. (2) shall supersede the report given by the public analyst under sub-s. (1).

(4) Where a certificate obtained from the Director of the Central Pood Laboratory under sub-s. (2) is produced in any proceeding under this Act or under Ss. 272 to 276 of the Indian Penal Code (45 of 1660) It shall not to necessary in such proceeding to produce any part of the sample of food taken for analysis.

(5) Any document purporting to be a report signed by a public analyst, unless it has been superseded under sub-section (3), or any document purporting to be a certificate signed by the Director of the Central Food Laboratory, may be used, as evidence of the facts stated therein in any proceeding under this Act or under sections 272 to 276 of the Indian Penal Code (45 of 1860).

Provided that any document purporting to be a certificate signed by the Director of the Central Food Laboratory shall be final and conclusive evidence of the facts stated therein.

Note:—It would not be proper to deny the accused right of cross-examining Public Analyst. Where such an opportunity is not afforded, the opinion of the public Analyst would carry little weight and would not be an adequate basis for conviction.”

14. It is not disputed that the Food Inspector (P.W 2) complied with the provisions of ss. 10 and 11. Formalin was added as a preservative to the milk in compliance with the provisions of Rule 20. The first attack is that Rule 18 was not complied with. The argument is based on the evidence that a copy of the memorandum and a specimen impression of the seal used to seal the packet was not separately sent to the Public Analyst. Reliance was placed on A.I.R 1951 Nag. 191, Dattappa Mahadappa v. Secretary, Municipal Committee Buldana, A.I.R 1964 Guj. 136, State v. Shantaben and 31 Cut LT 1008 : (AIR 1966 Ori 188), These decisions lay down that prosecution must establish that the specimen impression of the seal used to seal the packet was sent separately to the Public Analyst and that he compared the seal on the container and the outer cover with the specimen impressions received separately as enjoined upon in Rule 7(1). The proposition in its bald form is correct and cannot be questioned. These decisions, however did not examine whether in the absence of any direst evidence of the aforesaid facts, the Court can come to a conclusion that sales 7 and 8 were complied with, with reference to the report of the Public Analyst submitted in form No. Ill prescribed under Rule 7(3).

15. Form No. III may be quoted:—

“FORM III”

Report by the Public Analyst

Report No.………

I hereby certify that I Public Analyst for duly appointed under the provisions of the Prevention of Food Adulteration Act, 1954, received on the day of 9 from a sample of for analysis, properly sealed and fastened, and that I found the seal intact and unbroken.

I further certify that I have/have caused to be analysed the aforementioned sample, and declare the result of the analysis to be as follows:

and am of the opinion that Signed this day of 19 Address

(Signature) Public Analyst

16. Under S. 13(5), the report of the Public Analyst unless superseded by the certificate of the Director of the Central Food Laboratory may be used, as evidence of the facts stated therein any proceeding under the Act.

17. The material facts stated in the report pertaining to Rules 7 and 18 are that the Public Analyst certified that the sample was properly sealed and fastened, and that he found the seal intact and unbroken. This certificate is given by the Public Analyst under Rule 7(3) after the conditions laid down in Rule 7(1) & (2) are fulfilled. In other words, on receipt of the packet containing the sample for analysis from Food Inspector or any other person, the Public Analyst shall compare the seal on the container and the outer conver with specimen impression received separately and shall note the condition of the seals thereon. Thereafter, under sub-rule (2) he would make the analysis and then he would send the report in Form No. III. The report in Form No. III is thus preceded by certain ostensible acts which are, (i) comparison as prescribed in sub-rule (1) and (ii) analysis referred to in sub-rule (2) of Rule 7 of the Rules. The report of the Public Analyst is thus by itself evidence of fact of the compliance of Rules 7(1) and 18.

18. Added to this, the presumption under S. 114 of the Evidence Act may be invoked by the Court. The court may presume the existence of any fact which it thinks likely to have happened, regard being had to the common course of natural events, human conduct and public and private business, in their relation to the facts of the particular case. Illustration (e) appended to the Section is that the Court may presume that judicial and official acts have been regularly performed.

19. From the certificate of the public Analyst given in the report, presumption can be drawn particularly with reference to the mandatory procedures that in the absence of evidence to the contrary, the Court would presume that rules and legal formalities were complied with as the officer is not presumed to deviate from the rules and formalities laid down for his guidance (See AIR 1928 Mad 77—Sona chalam Piliai v. Kumaravalu Chettiar).

20. The same view has been taken in 32 Cut LT 18 : (AIR 1966 Ori 81), State v. Uma Charan, though all the reasons discussed above were not mentioned therein. I am inclined to accept that decision as laying down the correct law. For clarity, the position may be summed up. Prosecution may lead positive evidence that the conditions prescribed in Rules 7(1) and 18 were fulfilled. If, however there is dearth of such evidence for the prosecution, in the absence of contrary evidence, the report of the Public Analyst would be proof of the compliance of provisions of Rules 18 and 7(1).

21. The first condition has no substance and is accordingly rejected.

22. To appreciate the second contention, certain facts are to be stated. Samples were taken on 15-6-1963. A part of the sample was despatched to the Public Analyst under S. 11, sub-section (1)(c)(ii) for analysis. The Public Analyst submitted his report on 29-8-1963. Prosecution was launched on 5-12-1963. Thus, about five and half months elapsed from the date of seizure till the date of the prosecution. On the aforesaid facts, two contentions are advanced. Firstly, by the time the Public Analyst made analysis, the milk had decomposed—on decomposition, the constituent elements were changed and accordingly the report of the Public Analyst cannot be basis of conviction.

23. Rule 5 lays down that standards of quality of the various articles of food specified in Appendix B to these rules are as defined in that Appendix.

A. II deals with milk and milk products—

A. II-O. 101 runs thus:—

“Cow milk shall contain not less than 3.5 per cent of milk fat, except in Orissa, where it shall be not less than 3 per cent and in Punjab and Pepsu where it shall be not less than 4.0 per cent. The milk solids other than milk fat shall be not less than 8.5 per cent.”

24. The report of the Public Analyst shows that the fat content in the sample was 1.8 per cent, and the milk solids other than milk fat constituted 7.9 per cent. It is on this comparison the Public Analyst is of opinion that the milk in the sample was adulterated.

25. To get over this difficulty the contention advanced that the analysis was made by the Public Analyst about 21/2 months after when the milk had decomposed resulting in variation of the fat and other constituents. There are no materials in support of such an argument. Formalin was added as a preservative. Though the report of the Public Analyst constitutes evidence under the Act, even without his being examined as a witness in the court, it was open to the petitioner to summon the Public Anaiyst and cross, examine on relevant matters to establish the proposition that at the time of examination the milk in the sample had decompoeed and did not constitute the basis of a comparison with the standards of quality. No authoritative literature on the point has been placed before me to reach the conclusion that despite the prescribed preservatiy ‘formalin’ as prescribed in Rule 20 being added the milk had decomposed for analysis. This part of the contention is accordingly rejected.

26. The next point argued is that though the-report of the Public Analyst was seat on 29.8.1963, soon after the analysis of the sample, prosecution was launched on 5-12-1963 about mom than three months after. As a result of delayed prosecution, the petitioner was deprived of the opportunity of sending or challenging the report of the Public Analyst by asking for further analysis by the Director of the Central Food Laboratory whose certificate would statutorily supersede the report of the Public Analyst. This, contention is supported by AIR 1967 SC 970, Municipal Corporation Of Delhi v. Ghisa Ram. It is to be noted that the petitioner did not exercise his right in asking the court to send a part of the sample to the Director of the Central Food Laboratory. But as has been discussed in paragraph 7 of the Supreme Court decision, prosecution must be launched with prostitute be that the right given to the accused would not be illusory. Their Lordships observed thus:—

“In a case where there is denial of this right on account of the deliberate conduct of the prosecution, we think that the vendor, in his trial, is so seriously prejudiced that it would not be proper to uphold his conviction on the basis of the report of the Public Analyst, even though that report continues to be evidence in the case of the facts contained therein.”

27. The case related to ‘curd’. In paragraph 6 of the Judgment, their Lordships referred to the period after which it gets decomposed. Taking the observations in paragraph 6 into consideration, I am clearly of opinion that the milk would get decomposed, after a period of five and half months, even if the petitioner did not exercise his right under S. 13(2), no useful purpose would have been served by doing it after such a long time. In the facts and circumstances of this case, the delay in prosecution affected the petitioner's right to challenge the report of the Public Analyst which could be superseded by the certificate of a greater expert. The petitioner is entitled to take advantage of the aforesaid defect of the prosecution. He is entitled to benefit of doubt. In the result the order of conviction and sentence is set aside and the revision is allowed.

IK/BNP/D.V.C

28. Revision allowed.

Satrughna Behera v. Puri Municipality Opposite Party.

Structured Summary of the Opinion

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Petitioner's Arguments

Prosecution / Court-Noted Position

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

Satrughna Behera v. Puri Municipality Opposite Party.

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