In Brief
Mahyco Vegetable Seeds Ltd challenged criminal proceedings under the Seeds Act, 1966 after a seed sample seized on 1 September 2002 was analysed on 26 September 2002 but a complaint was not filed until 31 January 2003—by which time the sample's shelf life (7 November 2002) had expired. Section 16(2) grants the accused a statutory right to seek reanalysis at the Central Seed Laboratory. The Court held that loss of shelf life before filing the complaint deprived the accused of this mandatory right, rendering the prosecution futile. The appeal was allowed and criminal proceedings quashed."
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