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Issues:
1. Maintainability of the complaint filed by the Consumer Action Group regarding misbranding of food products under the Prevention of Food Adulteration Act. 2. Interpretation of Section 20 of the Act leading to a difference of opinion between the judges. 3. Validity of the sanction for prosecution granted by the Director Health Services and its impact on the trial court proceedings. Analysis: 1. The Consumer Action Group filed a complaint alleging misbranding of Cadbury's Butter Glucose Biscuits purchased from a store, leading to contravention of the Prevention of Food Adulteration Act. The trial court took cognizance of the matter and issued process against the accused. However, the Supreme Court found that the complaint was not maintainable due to lack of essential details, such as the brand name of the biscuits in the cash memo. Therefore, the court upheld the High Court's decision to quash the complaint based on this ground. 2. The appeal was initially heard by a Division Bench, but due to a difference of opinion on the interpretation of Section 20 of the Act, it was referred to a three-Judge Bench. The Supreme Court, however, did not delve into this issue as the complaint's maintainability was the primary concern. 3. The Director Health Services granted sanction for the prosecution of one accused only, but the trial court issued process against multiple accused without proper sanction. The Supreme Court noted the absence of sanction for some accused and highlighted the trial court's oversight in not considering this aspect before proceeding. Due to these procedural irregularities, the court agreed with the High Court's decision to quash the proceedings against the accused. The Supreme Court dismissed the appeal, emphasizing the importance of proper factual basis and legal procedures in such cases.
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