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Case Number

Crl. Appeal No. 47C-DBA of 1981

Advocates

S.D. Bansal
Anil K.S. Panwar
Jagdev Sharma

Judges

C.S Tiwana
M.M Punchhi, JJ.

Acts

Section 16(1)(a)(i) of the Prevention of Food Adulteraiton Act
Act by Parliament Act No. 34 of 1976
clause (f) of section 2 (ia), an article
clause (1) and (m) of section 2 (ia)
Act No. 34 of 1976. Section 10
clauses (1) and (m) of section 2
section 2(1)(f), an article
clauses of Section 2(1)
rule 48-B of the Rules
rule 5 of the Rules,

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Smart Summary

Structured Summary of the Opinion (M.M. Punchhi, J.)

Factual and Procedural Background

The Chief Judicial Magistrate, Gurgaon acquitted the accused-respondent, Rama Nand, of an offence under Section 16(1)(a)(i) of the Prevention of Food Adulteration Act. The prosecution arose after a Food Inspector visited the respondent's shop on 2 December 1977 and purchased a 600 gram sample of "Sabat Haldi" (turmeric fingers) from stock of 18 kg kept in a gunny bag. The sample was divided into three parts, secured, and one part sent to the Public Analyst. The Public Analyst received the sample on 6 December 1977 and analysed it on 12 January 1978. The analyst's report found insect-damaged matter of 7.7% (against the maximum prescribed standard of 5%) and recorded one living weevil and one dead meal worm, but the report did not state whether the article was injurious or non-injurious to health.

At trial the Food Inspector and an accompanying witness gave evidence; the accused was acquitted by the Chief Judicial Magistrate relying on the Supreme Court judgment in Municipal Corporation of Delhi v. Kacheroo Mal and on a Single Judge's decision in Vijay Kumar v. State of Punjab. The State of Haryana appealed. At the admission stage the State relied on the later Supreme Court decision in Municipal Corporation of Delhi v. Tek Chand Bhatia to contend that Kacheroo Mal was no longer a binding precedent; the appeal was admitted and placed before the High Court.

Legal Issues Presented

Whether, in the case of a primary food (such as whole turmeric), the presence of insect-infestation alone (under clause (f) of section 2(1)(ia)) renders the article adulterated irrespective of any finding as to its fitness for human consumption, in light of the statutory amendments made by Parliament (Act No. 34 of 1976).
How the amended clauses (1) and (m) of section 2(1)(ia) and the proviso—introducing the concept of "primary food" and standards/exemptions—interact with clause (f) for determining culpability and penal consequences.
Whether the Public Analyst's report, which recorded percentage insect damage but did not state whether the article was injurious or non-injurious to health or whether the damage was due to human agency, sufficed to sustain a conviction under the Act.
Whether the Food Inspector had the power to take a sample of primary food under the substituted provision of section 10(2) (Act No. 34 of 1976) when the article was not intended for sale "as such food."
Whether the earlier authority of Kacheroo Mal remained binding in light of the later Supreme Court decision in Tek Chand Bhatia and the statutory amendments.

Arguments of the Parties

State (Appellant) — Principal Contentions

The State relied at the admission stage on the later Supreme Court decision in Municipal Corporation of Delhi v. Tek Chand Bhatia to argue that the earlier decision in Municipal Corporation of Delhi v. Kacheroo Mal was no longer a binding precedent and thus the acquittal ought to be reversed.

Accused / Respondent — Principal Contentions

The accused's acquittal below was founded on the Supreme Court decision in Kacheroo Mal and on the Single Judge's decision in Vijay Kumar v. State of Punjab; those authorities were relied on to support the conclusion that the prosecution had not established the necessary elements to convict.

Table of Precedents Cited

Precedent	Rule or Principle Cited For	Application by the Court
Municipal Corporation of Delhi v. Kacheroo Mal (1975, 1975 (II) Food Adulteration Cases 223)	The Supreme Court held that the phrase "or otherwise unfit for human consumption" must be read conjunctively with preceding words; proof of unfitness for human consumption is required to bring a case within that part of the definition.	The trial court had relied on this case to acquit the accused. The High Court examined Kacheroo Mal but noted that later statutory amendments and subsequent decisions required re-examination of its scope; the High Court did not base its final decision solely on Kacheroo Mal but proceeded on its own reasoning applying the 1976 amendments.
Municipal Corporation of Delhi v. Tek Chand Bhatia (1979, 1979 (II) All India Prevention of Food Adulteration Cases 218)	The Supreme Court explained Kacheroo Mal as confined to its facts and held (as applied in the opinion) that under clause (f) whatever the degree of insect infestation an article may be deemed adulterated (i.e., no separate finding of unfitness may be necessary in that context); Tek Chand also noted applicability of specific rules framed for particular articles.	The State invoked Tek Chand Bhatia to contend that Kacheroo Mal was no longer binding. The High Court acknowledged Tek Chand's explanation of Kacheroo Mal but ultimately based its disposal on interpretation of the 1976 amendments (clauses (1) and (m) with the proviso) rather than on Tek Chand or Kacheroo Mal directly.
Vijay Kumar v. State of Punjab (1977, 1977 (II) Prevention of Food Adulteration Cases 117)	This judgment of a Single Judge of the High Court was relied upon by the trial court alongside Kacheroo Mal in acquitting the accused; no specific principle from the judgment is detailed in the opinion.	The trial court relied on this decision for acquittal. The High Court noted the reliance but did not set out any distinct rule taken from it; the High Court's decision rested on statutory interpretation and the deficiencies in the analyst's report.
Prem Bhallab v. The State (Delhi Admn.) (1977) 1 SCC 173	The Supreme Court observed that different clauses of Section 2(1) (as it then was) are not mutually exclusive and may overlap; an article may be found adulterated under more than one clause.	The High Court cited this case for the proposition that clauses of section 2(1) are not mutually exclusive and may overlap. However, the High Court held that the 1976 amendments (notably clauses (1) and (m) and the proviso regarding primary food) altered the interplay between clauses so as to render the overlapping-enunciation inapplicable insofar as primary food is concerned.

Court's Reasoning and Analysis

The court's analysis proceeded by close statutory construction of the Prevention of Food Adulteration Act as amended by Parliament Act No. 34 of 1976 and of the Rules framed thereunder.

Definitional framework and amendments:
- The court observed that by Act No. 34 of 1976 clause (i) was renumbered as (ia), sub-clause (f) (insect-infested) remained but clauses (1) and a new clause (m), together with a proviso, were introduced. A definition of "primary food" (xii-A) was also added, meaning produce of agriculture or horticulture in its natural form.
- The Joint Committee report (quoted by the court) demonstrated Parliament's intent to treat primary food differently—exempting primary food that is non-injurious to health and sub-standard due to natural causes beyond human agency, and to calibrate punishments according to nature of adulteration.
Statutory standards and the specific product:
- The court held that Sabat Haldi (whole turmeric) is a primary food and quoted Appendix B (rule 5) which prescribes that insect damaged matter in turmeric whole shall not exceed 5% by weight.
- Thus, for clauses (1) and (m) the prescribed standard for turmeric permits up to 5% insect damaged matter; a percent beyond that would indicate falling below prescribed standards, subject to the proviso.
Tension between clause (f) and clauses (1) and (m):
- The court recognized an apparent conflict: clause (f) treats an insect-infested article as adulterated without further finding, while clauses (1) and (m) incorporate standards and the proviso protecting certain primary foods from being deemed adulterated if degradation is due to natural causes beyond human agency.
- While Prem Bhallab had noted overlapping clauses, the court concluded that the 1976 amendments placed primary food at a different level and, effectively, clauses (1) and (m) with the proviso must be applied to primary food first—thereby limiting the application of clause (f) in respect of primary food.
Application to the evidence in the present case:
- The analyst reported 7.7% insect-damaged matter (over the 5% standard) plus one live weevil and one dead meal worm. However, the analyst's report did not state whether the article was injurious or non-injurious to health, nor did it indicate whether the insect damage was due to human agency.
- The court emphasized that when the quality or purity falls below the prescribed standard (clauses (1) and (m)), the report must specify whether the deficiency renders the article injurious or non-injurious to health and whether it was due to natural causes beyond human agency (so that the proviso might apply). The absence of such findings made the report deficient for purposes of convictions under the amended provisions.
- The court also noted factual possibilities consistent with natural causes: the sample was kept in a gunny bag and insects could have entered from outside or germinated within the article—natural occurrences which the proviso contemplates. The court considered it "wholly chimerical and inconceivable" that an adulterator would deliberately add insects to gain profit, supporting the plausibility of natural causes.
Limitation on inspection powers of Food Inspectors:
- Section 10(2) as substituted by the 1976 amendment includes a proviso that "no sample of any article of food being primary food, shall be taken under this sub-section if it is not intended for sale as such food". The court interpreted this as a deliberate curtailment of the Food Inspector's powers regarding primary food and as providing protective space for producers/keepers of primary food when not intended for sale "as such".
- That statutory limitation was factually relevant in assessing the lawfulness and sufficiency of the seizure/sampling and the overarching statutory scheme protecting primary food under certain conditions.
Precedent interaction and the court's basis for decision:
- The court acknowledged Tek Chand Bhatia's explanation of Kacheroo Mal and the State's reliance on it, but explicitly stated that its own decision was founded on application and interpretation of clauses (1) and (m) read with the proviso—preferentially to clause (f)—and on the deficiencies of the analyst's report. Thus the court did not rest the decision solely on prior Supreme Court authority but on statutory construction and evidentiary shortcomings.

Holding and Implications

Holding: APPEAL DISMISSED.

Implications and direct consequences:

The acquittal of the accused-respondent is maintained; the appeal by the State of Haryana fails.
For primary foods (such as whole turmeric), the court applied the amended statutory framework (clauses (1) and (m) with the proviso and the definition of "primary food") and treated those provisions as paramount in adjudicating alleged adulteration, requiring consideration of prescribed standards, injuriousness to health, and whether sub-standard condition arose from natural causes beyond human agency.
The court held that a Public Analyst's report which notes deviation from prescribed standards (e.g., percent insect damage) but does not state whether the article is injurious or non-injurious to health or whether the condition resulted from human agency is deficient for sustaining a conviction under the amended provisions.
The substituted proviso to section 10(2) limits a Food Inspector's power to take samples of primary food unless the article is intended for sale "as such food"; this limitation is relevant to protecting producers/keepers of primary foods from harassment and bears on the lawfulness and consequences of sampling and seizure.

Note on precedent and broader law: The court recognized and discussed prior Supreme Court authorities (Kacheroo Mal and Tek Chand Bhatia) and a High Court single-judge decision relied upon below, but expressly grounded its decision in statutory interpretation of the 1976 amendments and on the evidentiary deficiencies in the analyst's report rather than relying exclusively on any single precedent.

Appeal dismissed.

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State Of Haryana v. Rama Nand .

M.M Punchhi, J.:— The Chief Judicial Magistrate, Gurgaon acquitted the accused-respondent Rama Nand of the charge under Section 16(1)(a)(i) of the Prevention of Food Adulteraiton Act relying on the judgment of the Supreme Court in Municipal Corporation Of Delhi v. Kacheroo Mal ., 1975 (II) Food Adulteration Cases 223. The sample of ‘Sabat Haldi’ taken from the respondent on 2-12-1977 was found by the Public Analyst to contain insect damaged fingers 7.7 per cent against the maximum prescribed standard of 5.0 per cent, besides one living weavil and one dead meal worm. The report of the Public Analyst was silent whether the article was unfit for human consumption or otherwise injurious or non-injurious to health. The State of Haryana appealed and relied at the admission stage on a later decision of the Supreme Court in Municipal Corporation of Delhi v. Tek Chand Bhatia, 1979 (II) All India Prevention of Food Adulteration Cases 218, to contend that Kacheroo Mal's case (supra) was no longer a binding precedent in view of the later judgment in Tek Chand Bhatia's case (supra). It is in these circumstances that the appeal was admitted and has been placed before us.

2. The facts are straight and simple. The accused-respondent aged about 70 years is a shopkeeper at Retail Market, Hali Mandi. Gurgaon. On 2-12-1977, the Food Inspector visited his shop and found him to be in possession of 18 kgs. of ‘Sabat Haldi’ (turmeric fingers) for sale contained in a gunny bag : The Food Inspector served the requisite notice in accordance with the Food Adulteration Rules and purchased 600 gms. of ‘Sabat Haldi’ for analysis. The same was divided into three equal parts and bottled in three dry and clean bottles which were duly labelled and stoppered and security fastened. The Public Analyst to whom one such sample sent, received the sample on 6-12-1977 and caused it to be analysed on 12-1-1978, after a period of one month and six days. The result of his analysis has been noticed earlier. The respondent on that score was prosecuted on complaint failed by the Food Inspector who supported it, by his own evidence as P.W 1, by Dr. S.P Ghai, P.W 3 accompanying him, and the report of the Public Analyst. As said before the accused was acquitted on the strength of Kacheroo Mal's case (supra) as also on a judgment rendered by a Single Judge of this Court in Vijay Kumar v. State Of Punjab , 1977 (II) Prevention of Food Adulteration Cases 117. The appellant State of Haryana prays for the reversal of judgment and conviction of the accused-respondent in view of Tek Chand Bhatia's case (supra). The charge against the respondent was that he had contravened the provisions contained in Section 7 of the Act and the Rules framed thereunder and committed an offence under section 16(1)(a)(i) of the Act. It would now be apt to examine alleged contravention as also the provisions which make his act culpable.

3. To begin with, under section 2(1)(f), an article of food was deemed to be adulterated if the article consists wholly or in part any filthy, putrid, disgusting, rotten, decomposed or diseased animal or vegetable substance or in insect infested or is otherwise unfit for human consumption. In Kacheroo Mal's case (supra), the Supreme Court held that the phrase “or otherwise unfit for human consumption” should be read conjunctively and not disconjunctively in association with what precedes it. It was held that proof of the unfitness of the article for human consumption is a must for bringing the case within its purview. Later, by Parliament Act No. 34 of 1976, changes were brought about in section 2 of the Act in as much as clause (i) was renumbered as clause (ia) and sub-clauses (f) was remodelled so as to exclude therefrom the words “disgusting”. In addition thereto, underlined qualifications were added to subclauses (1) and a new sub-clause (m) was added, along with a proviso, which may be noted herein:—

“2(i) (1) if the quality or purity of the article falls below the prescribed standard or its constituents are present in quantities not within the prescribed limit of variability, which renders it injurious to health:—

(m) If the quality of purily or the article falls below the prescribed standard or its constituents are present in quantities not within the prescribed limits of variability but which does not render it injurious to health:

Provided that, where the quality or purity of the article, being primary food, has fallen below the prescribed standards or its contituents are present in quantities not within the prescribed limits of variability, in either case, solely due to natiral causes and beyond the control of human agency, then such article shall not be deemed to be adulterated within the meaning of this sub-clause;

4. Additionally, the definition of “primary food” was given in clause (xii-A) which too may be noted:—

(xii-A) ‘primary food’ means any article of food, being a produce of agriculture or horticulture in its natural form :”

5. These charges have been brought about by the Parliament seemingly on the report of the Joint Committee on the Prevention of food Adulteration (Amendment) Bill, 1974 published at page 10 of the Gazette of India Extraordinary, Part II, of January 5, 1976. Clause 12 thereof, which is relevant for the purpose, would be worthy of being taken note of:—

“The Committee has given very carefull thought on the provisions suggested in the clause relating to the penalties to be awarded for various types of offences under the Act. The Committee is of the opinion that while persons who indulge in deliberate acts of adulteration should be punished severely, it should, at the same time, be ensured that innocent people are not unnecessarily harassed. The committee has accordingly, categorised the offences under the Act and the punishments to be provided for them with reference to the nature and extent of the injuries suffered by the person consuming an adulterated food or adulterant as follows'—

(i) Primary food which is non-injurious to health but sub-standard due to natural causes and beyond the control of human agency, has been totally exemnfed. Such articles of food have been excluded from the definition of the term ‘adulterated’ also [vide proviso to sub-clause (b) (iii) (m) of clause 2 of the Bill.]

(ii) If the adulterated food is primary food which is non-injurious to health, but adulterated by human agency, the person committing the offence shall be liable to imprisonment for a term which shall not be less than six months but which extent to two years and shall also be liable to a fine of not less than rupee five hundred.

(iii) If the adulterated food is not primary food, and is non-injurious to health, the person committing the offence shall be liable to imprisonment for a term which shall not be less than six months but which may extend to three years and shall also be liable to fine of not less than rupees one thousand.

(iv) If the adulterated food is injurious to health but which does not cause grievous hurt or death, the punishment shall vary from one year to six years with a minimum fine of rupees two thousand.

(v) If the adulterated food is injurious to health and is likely to cause death or grievous hurt, the punishment shall vary from three years to life imprisonment with a minimum fine of rupees five thousand.

The committee has also brought within the ambit of the clause the import, manufacture, sale, storage, distribution of adulterants and has prescribed penalties for such offences.

The Committee has amended the clause accordingly.”

6. Now there can be no manner of doubt that Sabat Haldi is a primary food, it being a produce of agriculture and in its natural form. In Appendix ‘B’ prepared under rule 5 of the Rules, item A. 05.20 defines Sabat Haldi as under:—

“Turmeric (Haldi) whole means the dried rhizome or bulbous roots of the plant of curcoma longa L. It shall be free from lead chromate and other artificial colouring matter. The proportion of extraneous matter shall not exceed 2.0 per cent by weight.

The amount of insect damaged matter shall not exceed 5 per cent by weight.

Explanation—The term insect damaged matter ‘means spices that are partially or wholly bored by insects.”

7. There can be no manner of doubt that turmeric whole even in the dried state would be in its natural farm and be ‘primary Food’. Now under clause (f) of section 2 (ia), an article of food which is insect-infested would be deemed to be adulterated, and the there has to be no further finding that it was unfit for human consumption as per rule laid down by the Supreme Court in Tek Chand Bhatia's case (supra). In other words, whatever the degree of insect infestation, the article of food would be adulterated. As held in Kacheroo Mal's case (supra), the presence of deador alive insects would not make any difference and the article would be all the same insect-infested. Thus the presence of a live weavil and a dead meal worm in the sample as also insect damaged turmeric fingers, as found, would render the article adulterated. But what is the effect of clause (1) and (m) of section 2 (ia) is to be seen.

8. Prior to 2-10-1976, there was no standard of quality or purity prescribed for whole turmeric. But vide Notification No. GSR 14-17 of 20th September, 1976, it was provided with effect from 2-10-1976 that the amount of insect damaged matter in turmeric whole shall not cxceed 5 per cent by weight. And as per the explanation added there to, the term insect damaged matter’ meant spices that are partially or wholly bored by insects. Thus for the purposes of clauses (1) and (m) of section 2 (ia), the standard prescribed for turmeric whole permits the article to be partially or wholly bored by insects but upto 5 per cent by weight. In other words, turmeric whole fingers which are partially or wholly bored by insects, whether the insects therein be dead or alive, wou'd be within the prescribed standards of quality or purity and would not visit any penal consequences on the seller But conversely under clause (f) of section 2 (ia), even the slightest insect infestation would make the seller's act culpable. Thus it appears to us, these two clauses are in conflict with each other. But in Prem Bhallab v. The State (Delhi Admn.), (1977) 1 Supreme Court Cases 173, the Supreme Court had observed that the different clauses of Section 2(1) (as it then was) are not mutually exclusive and they overlap one another making it quite possible that an article of food may be found adulterated under two or more clauses of the said section. And here section 2 (ia) (f) makes the article adulterated but clause (I) and (m) thereof (subject to other conditions fulfilling) are canable or rendering it not so.

9. The Parliament in its wisdom by causing the amendment in 1976 considered it proper to place ‘primary food’ at a different level for purposes of the Act. As is plain from the report of the Joint Committee, extracted above, primary food, which is non injurious to health, but sub-standard due to natural causes and beyond the control of human agency, has totally been exempted from the purview of the Act. Such articles of food have been excluded from the definition of the term ‘adulterated’. The proviso added after clause (m) of section 2 (ia) makes th t abundantly clear. Primary food which is non-injurious to health, but adulterated by human agency, attracts on the person committing the offence a lessor punishment, as is plain from the language of section 16(1) (a) (i) of the Act. On the other hand, if primary food is adulterated but which is injurious to health, then the normal sentence as prescribed under section 16 is imposable. If adulterated food is not primary food, then other considerations apply which we are not concerned in the present case.

10. Reverting to the facts of the present case, the Public Analyst has reported that turmeric fingers were insect damaged upto 7.7 per cent. Presumably what he meant by the percentage was by weight and not by count. Nowhere has he said whether the article with such percentage of damage was injurious to health or non-injurious to health, or that the presence of insects or adulteration caused by insect damaging, was due to human agency. The article of food, if attacked by insects, whether germinated from within the article or visited from without, would first get insect-infested and then insect-damaged. It would thus seem to us to be defeating the intention of the law-makers by employing clause (f) of section 2 (ia) merely be insect infection and not making the proviso applicable in relation to primary food. Rather, it would promote the intention of the law-makers to initially apply clauses (1) and (m) read with the proviso to primary food, and then see if it is sub-standard due to natural causes and beyond the control of human agency, to be outride the purview of the Act and the Rules. But still, if the quality of the purity of the article is below the prescribed standard, the report of the Public Analyst would serve no purpose unless it specifies whether the same renders it injurious or non-injurious to health. Thus, “it appears to us that the amendment brought about in the Act by Parliament Act No. 34 of 1976 by bringing therein the concept of ‘primary food’ has rendered clauses (1) and (m) the twinssiamese to oust clause (f) in regard thereto, making the enunciation in Prem Bhallb's case (supra) with regard to overlapping of clauses inapplicable.

11. We must bring pointed attention to a curb put on the powers of the Food Inspectors by Parliament Act No. 34 of 1976. Section 10 gives powers of Food Inspectors. Sub-section (2) substituted by the amendment reads as follows:—

“Any Food Inspector may enter and inspect place where any article of food is manufactured, or stored for sale, or stored for the manufacture of any other article of food for sale, or exposed or exhibited for sale or where any adulterant is manufactured or kept, and take samples of such article of food or adulterant for analysis.

Provided that no sample of any article of food being primary food, shall be taken under this sub-section if it is not intended for sale as such food”.

12. It is thus obvious that a Food Inspector finding at a place any article of food being primary food, stored for sale, or stored for the manufacture of any other article of food for sale, or exposed or exhibited for sale, cannot take samples thereof unless such article was intended for sale as such food. The reason to put curbs on the powers of Food Inpector in relation to primary food conveys a salutary principle that such article of food, being in its natural form, is available for inspection to the naked eye to the seller as also the buyer. The seller of primary food, at any time, finding or suspecting it to have become adulterated within the meaning of the Act, can give out his intention that it is not meant for sale and barricade the Food Inspector from taking sample thereof. Similarly, a buyer of primary food, finding or suspecting the article to be adulterated within the meaning of the Act and the Rules, is capable of rejecting it, or according it in the condition as it is and then standardise the article at his own expense to confirm it to the quality and purity of the standard prescribed. The object is to safeguard producers and keepers of primary food from the harassment of the Food Inspectors and give them a protective umbrella if the article, being primary food, was not intended by them for sale as food for human consumption

13. Now here possibility cannot be ruled out that the turmeric fingers found with the petitioner could be visited by insects from outside lying as they were in a gunny bag wherein such article is normally stored or the insects to have germinated within. They could come there from without due to natural causes and beyond the control of human agency. It is wholly chimerical and inconceivable that an adulterator would add insects of his own to an article for profit making Also the report of the Public Analyst is deficient whether the article was injuriuos or non-injurious to health and thus does not carry out the purposes of either clauses (1) and (m) of the proviso in section 2(ia) of the Act. Such deficient report alone warrants us to maintain the order of acquittal of the respondent, besides other reasons mentioned heretofore.

14. To be fair to the learned counsel for the State-Appellant, it must be noticed that in Tek Chand Bhatia's case (supra), the Supreme Court had explained away Kacheroo Mal's case (supra) to be kept confined to the particular facts of that case as it was largely based on the circumstances that the standard of quality and purety in respect to the article involved therein had not been prescribed. The Supreme Court also noticed in Tek Chand Bhatia's case that in view of rule 48-B of the Rules having been framed on the subject of the said article, the decision in Kacheroo Mal's case (supra) was rendered inapplicable. As is by now clear, we haved based our decision not on the basis of the afore-referred to two cases of the Supreme Court, but on reasoning of our own applying the requirements clauses (1) and (m) read with the proviso in preference to clause (f) of section 2 of the Act

15. Thus for the foregoing reasons, this appeal fails and is hereby dismissed

Appeal dismissed.

State Of Haryana v. Rama Nand .

Structured Summary of the Opinion (M.M. Punchhi, J.)

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

State (Appellant) — Principal Contentions

Accused / Respondent — Principal Contentions

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

State Of Haryana v. Rama Nand .

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