Food import testing parameters are illustrative; writ courts will not reopen bona fide laboratory findings absent vitiating factors.

A Madras HC ruling on imported cocoa powder treated the Food Safety Regulations' testing parameters as illustrative rather than exhaustive and held that a rejection report was not vitiated merely because aluminium was not separately listed among the metals examined. The Court noted that the challenge was limited to the report's contents, no mala fides were alleged, and the regulations contemplated examination of metal contaminants. In writ jurisdiction under Article 226, the Court would not reappraise scientific conclusions absent other vitiating factors, so the laboratory rejection report was left undisturbed.

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Issues: Whether the rejection report issued by the Central Food Laboratory on imported cocoa powder was liable to be interfered with in writ jurisdiction on the ground that aluminium content was not among the stated testing parameters and that the report showed non-application of mind.

Analysis: The challenge was confined to the contents of the laboratory report and no mala fides were alleged against the testing officers. The standard testing parameters under the Food Safety Regulations were treated as illustrative and not exhaustive. The presence of additional constituents noticed during analysis could validly be reported, especially in the context of food products meant for wide public consumption. The Court further noted that the relevant regulation itself contemplated examination of metal contaminants, and the omission of aluminium from the listed metals did not invalidate the report. In writ jurisdiction under Article 226 of the Constitution of India, the Court would not sit in appeal over the scientific conclusions of the laboratory report in the absence of other vitiating factors.

Conclusion: The rejection report was not liable to be interfered with and the challenge failed.

Final Conclusion: The writ petition was dismissed, and the laboratory rejection report remained undisturbed.

Ratio Decidendi: A laboratory test report on food imports will not be invalidated in writ jurisdiction merely because it records a contaminant not expressly listed among illustrative testing parameters, so long as the report is otherwise bona fide and within the regulatory framework.

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