In Brief
In a criminal prosecution under the Seeds Act, 1966, the accused challenged proceedings relating to a seed sample taken on 1 September 2002. The sample's shelf life expired on 7 November 2002, but the complaint was filed only on 31 January 2003—after the sample became unusable. Section 16(2) grants the accused a statutory right to seek reanalysis at the Central Seed Laboratory. The Supreme Court held that by the time of the complaint, the sample had lost its shelf life, depriving the accused of this essential right. Such deprivation goes to the root of the matter and renders prosecution futile. Accordingly, the Court set aside the High Court's order and allowed the appeal, quashing the proceedings.
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