Article 14 challenge to zonal ghee standards fails where expert-based classification is not disproved.

Zonal food-quality standards for ghee framed under delegated rule-making were upheld as valid where they were based on expert consideration and supported by a statutory classification. A challenge under Article 14 on grounds of discrimination or unreasonableness requires proper pleadings and proof of material facts showing that the classification is infirm; absent such evidence, the Court will not substitute its own view for the standards fixed by the rule-making authority. The respondent produced no evidence to displace the presumption of validity, and the High Court was not justified in ignoring the prescribed zonal standards or applying the lowest Reichert value used anywhere in the country.

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Issues: Whether the zonal standards of quality prescribed for ghee under the Prevention of Food Adulteration Rules, 1955 could be ignored or treated as unenforceable on the ground of discrimination or unreasonableness under Article 14 of the Constitution, and whether the respondent's acquittal could be sustained on that basis.

Analysis: The statutory scheme empowered the Central Government to define standards of food quality and the rules framed under that authority prescribed different minimum Reichert values for different regions after expert consideration. A challenge to the validity of such a rule on the ground of unreasonableness or discrimination required proper pleadings and proof of material facts showing infirmity in the classification. In the absence of such foundation, the Court would not substitute its own view for the standards fixed by the rule-making authority, particularly where the standards were framed on expert advice. The respondent led no evidence sufficient to displace the presumption that the zonal classification and the prescribed standards were based on relevant considerations. The earlier approach that treated hilly terrain alone as decisive was incorrect, and the High Court was not justified in discarding the rule and applying the lowest Reichert value prescribed anywhere in the country.

Conclusion: The challenge under Article 14 failed, and the respondent's acquittal could not be sustained.

Ratio Decidendi: A statutory rule prescribing differential standards on expert advice is presumed valid, and a party assailing it on the ground of discrimination or unreasonableness must plead and prove the factual basis for invalidity before the Court can refuse to enforce it.

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