In Brief
This case resolved a conflict between food adulteration prosecutions under the Indian Penal Code (IPC) and the Food Safety and Standards Act (FSSA). An appellant challenged an FIR for selling adulterated mustard oil under IPC Sections 272-273. The Supreme Court held that Section 89 of the FSSA gives overriding effect to its comprehensive provisions over the IPC for food-related offences. Where conduct violates both statutes, prosecution must proceed exclusively under FSSA Section 59 (unsafe food), which provides more stringent punishment and broader coverage than IPC provisions. The Court set aside the impugned orders and quashed the IPC-based prosecutions, permitting authorities to pursue proceedings under the FSSA if not already initiated.
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