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Issues: Whether gingelly oil mixed with groundnut oil remained an article of food within the meaning of the Act, and whether its sale was punishable notwithstanding that it was stated to be intended for external use only.
Analysis: The definition of "food" was held to cover any article ordinarily used as food or in the preparation of human food, and the seller's description of the article as meant for external use was held not to be controlling where the article was generally or commonly used as food. The definition of "sale" was construed broadly to include all forms and purposes of sale, including sale for analysis, so that liability under the Act could not be avoided by asserting that the article was not sold for human consumption. The earlier authorities were explained as turning on their own contexts and not as requiring proof that the article was intended for human consumption in every case.
Conclusion: Gingelly oil mixed with groundnut oil was held to be "food" and its sale was punishable under the Act even though it was stated to be for external use only.
Ratio Decidendi: Under the Act, an article generally or commonly used as food is "food" irrespective of the seller's stated purpose, and the statutory definition of "sale" is wide enough to include sales for any purpose, including analysis.
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