Export quality-control conditions upheld as a reasonable restriction where APEDA registration clarified hygienic meat-export requirements.

The impugned export notification was challenged as discriminatory, ultra vires, and an unreasonable restraint on trade because it required meat and meat products to be sourced from APEDA-registered abattoirs or integrated abattoirs. The Court read the notification with the earlier export regime and the APEDA registration framework, and held that the requirement was clarificatory rather than a new burden. It was found to support the regulatory objective of ensuring quality, hygiene, and safety in exported meat, and to be directly connected with that purpose. The notification was therefore upheld as valid, non-discriminatory, and a reasonable restriction on business under Article 19(6).

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Issues: Whether the impugned notification requiring export of meat and meat products to be supported by APEDA registration of the source abattoir or integrated abattoir was discriminatory, ultra vires, or an unreasonable restriction on the right to carry on business.

Analysis: The notification was construed in the light of the earlier export regime and the registration procedure under APEDA. The requirement that meat for export be sourced from an APEDA-registered abattoir or integrated abattoir, and that the processing plant and source of raw material be duly registered, was held to be consistent with the object of ensuring quality, hygiene, and safety in export meat. The notification was treated as clarificatory, removing doubt created by the earlier wording, and not as introducing a new or discriminatory burden. The restriction was found to be directly connected with the regulatory purpose and permissible as a reasonable restraint on business.

Conclusion: The challenge failed. The notification was upheld as valid, non-discriminatory, and within statutory power, and the petition was dismissed.

Ratio Decidendi: A regulatory export condition that clarifies an existing quality-control requirement and is rationally connected to the statutory objective of ensuring hygienic and compliant exports does not violate Articles 14 or 19(1)(g) when it operates as a reasonable restriction under Article 19(6).

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