VidhiSangh

Supreme Court of India · 04/08/2021

M/S. CHEMINOVA INDIA LTD. & ANR. versus STATE OF PUNJAB & ANR.

[2021] 8 S.C.R. 352 · 2021 INSC 381

AI-generated headnote. Verify against the judgment before relying on it. Paragraph numbers refer to the judgment.

Summary

The Court quashed an insecticide-misbranding complaint filed more than three years after the Inspector received the first laboratory report showing deficient active ingredient. A later Central Insecticide Testing Laboratory report, obtained on the manufacturer’s request, did not postpone commencement of limitation. Continuing the facially time-barred prosecution would abuse the process of law. Other grounds urged for quashing were left undecided.

Issues

  1. Whether limitation began with the first competent laboratory report or the later report on re-analysis.

Provisions considered

Held

Result

Appeal allowed; High Court order set aside and Complaint No. 26 dated 25 March 2014 quashed.

Judgment PDF: Supreme Court of India, [2021] 8 S.C.R. 352.