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Supreme Court of India 2022-12-16 allowed

HASMUKHLAL D. VORA & ANR vs THE STATE OF TAMIL NADU

Bench: 2 — Krishna Murari, S. Ravindra Bhat

In Brief

The Supreme Court quashed a criminal complaint against the appellants, traders of raw material chemicals, for allegedly breaking bulk quantities of pyridoxal-5-phosphate into smaller packs and selling them without a manufacturing license. The Court held that the substance is a bulk food ingredient exempted under the Drugs and Cosmetics Act for dual-use substances, and the respondent failed to adduce scientific evidence that it is solely a drug. The appellants held valid wholesale licenses. The Court found the four-year unexplained delay between inspection and complaint, coupled with absence of supporting evidence, rendered the proceedings frivolous and an abuse of process, warranting quashing under Section 482 Cr.P.C.

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Criminal Procedure Drug Regulation Quashing of Criminal Complaints Drugs and Cosmetics Act Food Safety and Standards Act Abuse of Process Prosecutorial Discretion Administrative Law

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