Quashing of Criminal Proceedings under the Food Safety and Standards Act, 2006

Aadrikaa Legal Services (ALS)- Law I Litigation I Arbitration

Date: 10.08.2026

Quashing of Criminal Proceedings under the Food Safety and Standards Act, 2006

A recent judgment by the Delhi High Court has brought closure to long-standing criminal proceedings against various parties involved in the sale and distribution of MAGGI Noodles, stemming from the nationwide food safety controversy of 2015. This article provides a detailed overview of the case, the legal arguments, and the court’s reasoning that led to the quashing of the prosecutions.

Background: The MAGGI Noodles Controversy

In May 2015, Food Safety Officers in Delhi collected samples of MAGGI Noodles from retail outlets as part of a nationwide sampling exercise. The samples were tested, and initial reports from the Food Analyst indicated that the lead content in the masala tastemaker exceeded the permissible limit of 2.5 ppm. Additionally, some samples were alleged to be misbranded due to the “No Added MSG” label.

These findings led to criminal complaints against retailers, suppliers, and the manufacturer, Nestlé India Limited, under the Food Safety and Standards Act, 2006 (FSS Act). The accused sought to quash these proceedings, arguing that the basis for prosecution was no longer valid.

Legal Proceedings and Arguments

Petitioners’ Submissions

1. Invalidity of Laboratory Reports: Petitioners argued that the prosecution relied solely on Food Analyst reports from laboratories that were neither NABL accredited nor notified under Section 43 of the FSS Act, as required by law. This position was supported by the Bombay High Court’s 2015 judgment, which set aside the nationwide ban on MAGGI Noodles for similar reasons.
2. Subsequent Testing and Judicial Findings: Following the Bombay High Court’s directions, fresh samples were tested by accredited laboratories, all of which found the lead content within permissible limits. The Supreme Court also directed testing by the Central Food Technological Research Institute (CFTRI), which confirmed the product’s safety.
3. Supersession of State Laboratory Reports: Under Section 46(4) of the FSS Act, the Referral Food Laboratory’s report supersedes the Food Analyst’s report. Since the Referral Laboratory found the product compliant, the original reports lost evidentiary value.
4. Abuse of Process: Petitioners contended that continuing the prosecution would be an abuse of the court’s process, as the scientific foundation of the case had been undermined by subsequent findings and judicial pronouncements.

State’s Submissions

1. Procedural Compliance: The State argued that all sampling and testing procedures were followed as per the FSS Act, and the accused had the opportunity to seek referral analysis but did not exercise this right.
2. Validity of State Laboratory: The State maintained that, under transitional provisions, State Food Testing Laboratories could continue functioning until formal notification and accreditation, which was later obtained.
3. Independence of Criminal Proceedings: The State asserted that the criminal complaints were independent and should proceed to trial, as the issues involved required evidence and could not be decided summarily.

Court’s Analysis and Findings

The High Court examined the entire sequence of events and legal developments:

1. Judicial Scrutiny of Laboratory Reports: The Bombay High Court and Supreme Court had already scrutinized the validity of the laboratory reports and directed fresh testing by accredited and notified laboratories.
2. Referral Laboratory Findings: The CFTRI, a Referral Laboratory, found the lead content within permissible limits. The Supreme Court directed that these findings should form the basis for adjudication.
3. Erosion of Prosecution’s Foundation: The court noted that the prosecution was based solely on the original Food Analyst’s reports, which had been superseded and discredited by subsequent scientific and judicial review.
4. Abuse of Process: Continuing the criminal proceedings would serve no useful purpose and would amount to an abuse of the court’s process, as the very foundation of the prosecution had eroded.

The court also referenced similar decisions by the Himachal Pradesh and Uttarakhand High Courts, which quashed prosecutions arising from the same controversy.

Conclusion and Impact

The Delhi High Court allowed the petitions, quashing the criminal complaints, summoning orders, and all consequential proceedings. This judgment reinforces the importance of scientific rigor, statutory compliance, and judicial oversight in food safety prosecutions. It also provides clarity for businesses and consumers regarding the standards and processes that must be followed in such cases.

The decision marks a significant closure to the MAGGI Noodles controversy, emphasizing that prosecutions cannot continue when their scientific and legal basis has been invalidated by subsequent authoritative findings.

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Source: Delhi High Court

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