Delhi High Court Quashes Maggi Cases From 2015 Controversy

The Delhi High Court has quashed two criminal complaints arising from the 2015 Maggi noodles controversy, along with the trial court’s summoning orders and subsequent proceedings, holding that continuing the prosecutions would amount to an abuse of the process of law.

Justice Madhu Jain allowed petitions filed by Dharmendra Hansraj Kotak and others, setting aside the complaints and summoning orders dated November 6, 2015 and January 11, 2016.

The cases stemmed from Maggi samples collected by the Delhi Food Safety Department in May 2015 as part of a nationwide sampling exercise. The Food Analyst had reported that the lead content in the masala tastemaker exceeded the prescribed limit of 2.5 ppm. One of the complaints also alleged misbranding over the product’s “No Added MSG” declaration.

The petitioners argued that the foundation of the prosecution had been weakened by subsequent judicial proceedings and fresh testing of Maggi samples. They relied on the Bombay High Court’s decision setting aside the nationwide Maggi ban and subsequent scientific testing carried out following directions from the Supreme Court.

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Cases Quashed:

The Delhi High Court noted that the Bombay High Court had held that laboratories conducting analysis under the Food Safety and Standards Act must meet statutory requirements, including NABL accreditation and notification under Section 43 of the Act.

Following the Supreme Court’s directions, fresh scientific evaluation of the samples was conducted by CSIR-CFTRI, Mysuru, a notified referral food laboratory. The findings were subsequently considered by the National Consumer Disputes Redressal Commission (NCDRC) in proceedings initiated by the Union government, with the consumer complaint eventually dismissed.

The Delhi High Court observed that the Delhi prosecutions originated from the same nationwide sampling exercise and were based exclusively on the original Food Analyst reports. In light of the subsequent scientific evaluation and judicial developments, the Court found that the evidentiary foundation of those reports had been substantially weakened.

The State opposed the petitions, arguing that the complaints had been filed after following the prescribed procedure. It also contended that the petitioners had not sought referral analysis at the relevant stage and that decisions concerning the nationwide Maggi ban did not automatically invalidate separate criminal proceedings based on samples collected in Delhi.

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The Court, however, said that while criminal proceedings ordinarily operate independently, subsequent scientific findings and judicial developments could be considered while exercising inherent powers under Section 482 of the Code of Criminal Procedure.

The Court also took note of similar decisions by the Himachal Pradesh and Uttarakhand High Courts concerning criminal proceedings arising from the Maggi controversy.

Holding that continuing the cases would serve no useful purpose, the Delhi High Court quashed the two complaints, the summoning orders and all consequential proceedings pending before the trial court.