Obiter dicta are not binding precedent: stray Supreme Court observations cannot justify interference in food adulteration cases.

A casual or passing statement in an earlier Supreme Court decision does not become binding precedent under Article 141, especially when it merely supports the reasoning or relates to specific facts. The article explains that extracting one sentence out of context to defend a food adulteration acquittal is impermissible, because the earlier case did not lay down a rule that minor deficiencies in milk constituents necessarily require acquittal. It also notes that interference under Article 136 is unwarranted where no substantial question of public importance arises and the cited statement is not the ratio decidendi.

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Issues: Whether a casual statement in an earlier decision of the Supreme Court could be treated as the ratio decidendi so as to justify interference in a food adulteration acquittal, and whether the appeal warranted interference under Article 136 of the Constitution of India.

Analysis: The Court held that a statement made in passing, especially one relating to facts or used only to fortify the reasoning, does not become binding law under Article 141. The earlier decision relied upon by the appellant was concerned with the limits of revisional interference in a marginal case and did not lay down a rule that minor deficiencies in milk constituents necessarily entitle an accused to acquittal. Extracting a sentence from that judgment out of context and turning it into a defence in food adulteration prosecutions was found to be impermissible. The Court further noted that the appeal involved no substantial question of public importance and that the attempt to obtain a declaration on an obvious non-ratio point was unnecessary.

Conclusion: The alleged obiter could not be treated as binding precedent, and no interference was called for in the matter.

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