In Brief
This appeal examined whether offenders convicted under the Prevention of Food Adulteration Act (PoFA), 1954 could be released on probation or receive reduced sentences following changes in law. The Supreme Court held that Section 20AA of the PoFA Act, which explicitly bars the Probation of Offenders Act and Section 360 CrPC, prevents such relief for offences committed between 1976-2006. Further, where a repealing statute protects original penalties through a 'repeal and savings' clause, the new law's reduced punishments cannot be applied. However, the Court partly allowed relief where conflicting laboratory evidence cast doubt on adulteration findings, converting sentences from imprisonment to fines on equitable grounds.
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