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Issues:
Challenge to legality of judgment on framing charges under Essential Commodities Act, 1955. Analysis: The case involved a challenge by the State of Punjab against a judgment by a learned Single Judge of the Punjab and Haryana High Court. The petition questioned the correctness of the order passed by the Special Judge, Sangrur, framing charges against the accused for alleged violation of the Essential Commodities Act, 1955. The charge was framed based on the infringement of the Vegetable Oil Products Control Order, 1947, as amended under the Act. The accused persons, including a Production Manager and Directors of the company, opposed the framing of charges, arguing that only the Production Manager should face trial. The High Court quashed the charges against the Directors, finding no definite material to show their involvement in the business's running. The central issue revolved around the interpretation of Section 10 of the Act, which holds individuals responsible if a company contravenes an order. The section specifies that persons in charge of the company at the time of contravention shall be deemed guilty unless they prove lack of knowledge or due diligence. The Court emphasized that the person in charge or officers of the company could be separately prosecuted even if the company itself is not prosecuted. The judgment highlighted the importance of establishing a contravention by the company before holding individuals accountable. The Court referenced previous cases to explain the limited scope for interference with an order framing charges. It outlined the circumstances under which inherent jurisdiction may be exercised, such as to prevent abuse of court process or to secure the ends of justice. The judgment emphasized that inherent powers should be used sparingly and in line with specific criteria laid down in the law. The Court also cited categories of cases where inherent power should be exercised to quash proceedings, including lack of legal evidence or a legal bar against the continuation of proceedings. In conclusion, the Supreme Court held that the High Court was not justified in quashing the charges against the Directors. The Court clarified that its decision did not imply any opinion on the case's merits and directed the trial court to consider the evidence and materials presented by the parties in accordance with the law. The appeal was allowed to the extent that the charges against the Directors should not have been quashed.
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