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Issues: (i) Whether betel nuts imported for human consumption fall within the definition of "food" under the Food Safety and Standards Act, 2006. (ii) Whether, in the absence of a specific standard for betel nuts, the authorities can detain or refuse release of imported betel nuts on the ground that they are contaminated, adulterated, or otherwise unsafe for human consumption.
Issue (i): Whether betel nuts imported for human consumption fall within the definition of "food" under the Food Safety and Standards Act, 2006.
Analysis: The statutory definition of "food" is broad and covers any substance, processed or unprocessed, intended for human consumption. The determining factor is not immediate consumption but the ultimate intended human use. On that basis, betel nuts cannot be excluded merely because they may undergo further processing before consumption.
Conclusion: Betel nuts intended for human consumption fall within the definition of "food" under the Act.
Issue (ii): Whether, in the absence of a specific standard for betel nuts, the authorities can detain or refuse release of imported betel nuts on the ground that they are contaminated, adulterated, or otherwise unsafe for human consumption.
Analysis: The specific standards for dry fruits and nuts in the relevant regulations were held inapplicable to betel nuts, as betel nuts belong to a different class and are not covered by that category by the rule of ejusdem generis or noscitur a sociis. However, the absence of a specific standard does not disable the authorities from taking precautionary action where imported goods are found unsafe, contaminated, or injurious to health. Constitutional duties to protect life and health, together with international food-safety principles, support such protective action in appropriate cases.
Conclusion: The standards for dry fruits and nuts do not apply to betel nuts, but the authorities may still detain or refuse release of imported betel nuts if they are found unsafe for human consumption.
Final Conclusion: The writ petitions succeeded to the extent that betel nuts could not be tested against the dry-fruit and nut standards, but the Court preserved the authority's power to take protective action where imported goods are unsafe. As the goods had already been released under interim orders, no further relief was granted.
Ratio Decidendi: A substance is "food" under the Act if it is intended for human consumption, and in the absence of a specific standard the authorities may still invoke their protective function to prevent the entry of contaminated or unsafe food articles.